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    Authors
    Markus Böhme

    Dr. Markus Böhme, LL.M. (Nottingham)

    Partner

    Duesseldorf
    Read More

    Dr. Christian Ertel

    Salary Partner

    Munich
    Read More

    Fiammetta Kremer

    Associate

    Munich
    Read More
    Authors
    Markus Böhme

    Dr. Markus Böhme, LL.M. (Nottingham)

    Partner

    Duesseldorf
    Read More

    Dr. Christian Ertel

    Salary Partner

    Munich
    Read More

    Fiammetta Kremer

    Associate

    Munich
    Read More
    • On this page

    25 September 2025

    Publication series – 23 of 84 Insights

    Federal Network Agency discussion paper on reforming grid fees for industry and commerce

    • Quick read

    The Federal Network Agency has published a discussion paper (link) on the future structure of electricity network charges for industry and commerce. The aim is to replace the current band load regulation, which expires at the end of 2028, with a new system that provides incentives for more flexible consumption behaviour.

     

    Background

    Under Section 19(2) of the Electricity Network Access Ordinance (StromNEV), large electricity consumers currently receive network fee discounts if they consume a constant load for more than 7,000 hours per year. This so-called band load regulation is considered legally contestable, often prevents an economic response to price developments and expires on 31 December 2028 at the latest. A new regulation is therefore urgently needed.

     

    Proposed regulations

    The Federal Network Agency is putting forward three possible approaches for discussion:

    1. Market-oriented consumption behaviour – discounts for companies that align their consumption more closely with electricity price signals.
    2. Flexibility utilisation – discounts for the use of storage facilities or other measures for grid-friendly load control.
    3. Direct controllability – discounts if grid operators can access loads directly when necessary.

    All proposals have in common that they require a specific consideration, must not significantly impair production processes and should be supplemented by transitional arrangements.

     

    Status of the process and outlook

    The process of revising the regulations began in July 2024 and was integrated into the General Grid Fee System (AgNeS) in May 2025 to better coordinate general grid fees and special regulations for industry (further information here).

    • 30 September 2025: Industry workshop on the discussion paper
    •  21 October 2025: End of the consultation period

    Comments can be submitted by email to gbk@bnetza.de with the subject line “GBK-25-01-1#3; Name of your institution” until the end of the consultation period. The Federal Network Agency will publish the comments received on its website.

     

    Conclusion

    The planned changes are of considerable practical importance for industrial and commercial customers with high electricity consumption. In particular, the future structure of the discounts will depend largely on consumption behaviour and the flexibility offered.

    If you have any questions about the consultation or its possible impact on your company, we will be happy to advise you.

    Services and Groups Environmental, planning & regulatory
    Sectors Energy & infrastructure

    In this series

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    27 March 2026

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    12 November 2025

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    21 November 2025

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    23 September 2025

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    25 September 2025

    by Multiple authors

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    15 September 2025

    by Peter Solt, LL.M.

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    8 September 2025

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    18 August 2025

    by Johannes Schaadt-Wambach, LL.M. (Prag), Dr. Markus Böhme, LL.M. (Nottingham)

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    Regulatory Framework for Transmission System Operators in Germany

    18 August 2025

    by Multiple authors

    Battery Storage

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    11 August 2025

    by Dr. Christian Ertel

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    31 July 2025

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    31 March 2025

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    26 March 2025

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    CJEU judgement on customer installations in accordance with Section 3 No. 24a Law on the Energy Industry EnWG

    26 March 2025

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    28 November 2024

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    11 November 2024

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    27 September 2024

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    Land acquisition and data protection: The importance of the GDPR when project developers request owner data

    18 July 2024

    by Dr. Patrick Vincent Zurheide, LL.M. (Aberdeen), Dr. Julia Wulff

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    26 January 2024

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    6 November 2023

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    3 November 2023

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    1 September 2023

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    16 August 2023

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    Challenges for data center operators - The federal government’s draft bill for an energy efficiency act

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    10 June 2022

    by Prof. Dr. Norbert Kämper

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    27 April 2022

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    5 November 2021

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    18 August 2021

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    8 June 2021

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    9 March 2021

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    13 October 2025

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