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2026年5月26日
Publication series – 2 / 86 观点
THG quota 2026/2027 and beyond: What fleet operators need to know now - Focus electromobility
- Briefing
The greenhouse gas reduction quota (THG quota) is the central instrument requiring suppliers placing fossil petrol and diesel fuels on the market to reduce their emissions relative to a reference value. For companies with electric vehicle fleets – such as public transport bus operators, logistics companies or operators of large passenger car fleets – it is particularly relevant that electricity for electric vehicles can be counted as a compliance option and sold to obligated mineral oil companies as a quota reduction. These revenues can make a significant contribution to financing electric vehicles and charging infrastructure.
Legal framework
The legal basis for the THG quota is Sections 37a et seq. of the Federal Immission Control Act (BImSchG) and the 38th Federal Immission Control Ordinance (38. BImSchV). Suppliers placing fossil fuels on the market must gradually reduce the emissions of the quantities they place on the market. To fulfil this reduction obligation, they can, among other things, make use of verified GHG reductions from electricity for electric vehicles. The 38th BImSchV regulates how electricity volumes are recorded, converted into emissions and credited. Based on the amount of electricity, using an emission factor for electricity and a powertrain efficiency factor, a greenhouse gas reduction is calculated that can be used as a tradable “quota”.
The German Environment Agency (UBA) verifies the reported electricity volumes and issues certificates for the creditable reduction. On this basis, fleet operators or intermediaries conclude contracts with obligated companies.
The 2026 amendment: Higher ambition and targeted incentives for electricity
The “Second Act to Further Develop the GHG Quota” has increased the ambition level of the system from 2027 onwards. Obligated parties must reduce emissions by 65% by 2040. For obligated companies, this increases the need for cost-efficient compliance options – and thus the importance of electricity from electric fleets.
Central for fleet operators is the adjustment of the electricity multipliers. For passenger cars and light commercial vehicles, triple counting of electricity will initially remain in place: electricity in purely battery electric passenger cars and light commercial vehicles will continue to be counted with a factor of 3. From the mid 2030s, this factor will be gradually reduced to 2 and subsequently to 1. The disproportionately favourable treatment will therefore be phased out in the long term; however, the revenue leverage per vehicle will remain high until 2034. This is justified by the still ongoing need to incentivise electromobility, which is expected to decline over time.
For heavy electric vehicles, in particular e buses (M3) and heavy e trucks (N3), the amendment introduces an increased special multiplier from 2027 onwards. Electricity in these vehicles will be counted with a factor of 4, which will gradually decrease to 1 by 2040. In doing so, the legislator is creating targeted incentives for the ramp up of electrification in a segment that has so far decarbonised only slowly due to high investment costs and technical requirements.
Practical crediting
For fleet operators’ use of the GHG quota, the distinction between public and non public charging processes is decisive. In the case of public charging – for example at fast charging parks or municipal charging hubs – operators register their charging points with the Federal Network Agency and record the electricity volumes obtained there. On this basis, they apply to the UBA for the credit; the UBA certifies the creditable GHG reduction, which is then marketed.
In the case of non public charging – for example at depots, on company premises or at employees’ homes – standardised estimated values per vehicle are used. The prerequisite is that the vehicles are purely battery electric and that the relevant registration data is available. The UBA applies officially published estimates and factors and certifies the resulting GHG amounts. Fleet operators should keep a close eye on the relevant deadlines for UBA notifications and the conclusion of quota contracts in order not to miss revenue opportunities.
Additional potential arises if charging infrastructure is directly linked to renewable power generation. If electricity from wind or solar plants is used directly behind the same grid connection point for charging and the regulatory requirements are met, a lower specific emission factor can be applied. This increases the GHG reduction per kilowatt hour, but is technically and organisationally complex and is therefore particularly suitable for larger sites with their own renewable energy generation.
From 2028, electricity from biomass, landfill gas, sewage gas and biogas can also be taken into account when providing charging power, which increases flexibility for obligated parties in meeting their quota.
Economic implications for electric fleets
For operators of heavy electric fleets, the special multiplier will have a direct impact on the business case from 2027 onwards. E buses and heavy e trucks will generate significantly more GHG quotas per kilowatt hour or per standard value than before. These additional revenues can help offset higher acquisition and infrastructure costs. At the same time, the gradual reduction of the multiplier until 2040 must be taken into account in planning to avoid building on overly optimistic revenue expectations.
Passenger car fleets will continue to benefit from the triple counting of electricity until 2034. For car rental companies, car sharing providers and companies with large company car fleets, the GHG quota will remain a relevant revenue factor during this period. From 2035 onwards, the reduction of the multiplier will reduce the potential revenue per vehicle, so long term leasing and fleet strategies should factor in this development.
The design of the charging infrastructure is also gaining strategic importance. Where direct renewable power can be used, a higher GHG reduction per MWh is possible, provided that metering and balancing requirements are fulfilled. This can be particularly attractive for large depots or hubs with their own photovoltaics or connected renewable energy plants. At the same time, stricter controls and fees for UBA decisions are increasing the requirements regarding data quality, documentation and compliance.
Double counting of advanced biofuels
Notably, the amendment also recalibrates the role of advanced biofuels. The previous double counting of certain advanced biofuels is being abolished in order to avoid over subsidisation and to use scarce biomass potential more efficiently. This adjustment has an indirect effect on GHG market prices, as it shifts the relative attractiveness of different compliance options.
However, this deprives many quota marketing contracts already concluded of their economic basis and entails substantial potential for disputes. This is because quota buyers will receive only half the quotas for the same price. It is possible that quota marketers will seek contract adjustments on the basis of existing hardship or economic clauses or the statutory claims under Section 313 of the German Civil Code (BGB). If contracts lack sufficient provisions, the parties will have to rely on the statutory rules. Interpretation is not always clear, so the elimination of double counting will continue to rest on uncertain legal ground.
The risk that existing multiplication factors or double counting for quotas of certain energy carriers may be abolished also remains in place for existing contracts in the future. For pure electricity fleets, this means: electricity will remain a central option, but will compete with a somewhat “streamlined” range of biofuels and electricity based fuels.
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