Proceedings over failure to implement network tariff reductions for electric vehicles and heat pumps
Year of issue 2026
Date of issue 2026.05.28
The Bundesnetzagentur has issued warnings of coercive fines to two network operators on account of delays in implementing the provisions for network tariff reductions. The operators have not, or not adequately, implemented the provisions or incentives from the “NSAVER” determination on network tariffs for controllable network connections and consumer devices.
"The Bundesnetzagentur has laid down binding provisions for controllable consumer devices. The aim is to protect low-voltage networks from overloading and generate flexibility at the low-voltage level. We have found that companies have not, or not adequately, implemented our provisions, in particular for time-variable network tariffs. This is no longer acceptable,"
said Klaus Müller, President of the Bundesnetzagentur.
Initiation of administrative enforcement proceedings
The Bundesnetzagentur had received complaints about various companies from market players and consumers. This prompted the Bundesnetzagentur to verify implementation of the determination. Many of the complaints related to the arrangements for time-variable network tariffs under module 3 of the determination. Operators have been required to offer and charge tariffs under modules 1 and 2 since 1 January 2024 and under module 3 since 1 April 2025.
The Bundesnetzagentur makes use of the possibilities of administrative enforcement to ensure compliance with the provisions. The first two network operators in question have been issued a coercive fine warning and given until 30 September 2026 to eliminate the shortcomings. If they do not, the Bundesnetzagentur will set a coercive fine. The initiation of administrative enforcement measures against other network operators will follow successively following clarification of the cases. The initiation of proceedings is published on the competent ruling chamber’s web pages (in German): www.bundesnetzagentur.de/1107472
Background
The electrification of the heating and transport sectors is a key pillar of the energy transition. The spread of heat pumps and electric vehicles poses a particular challenge for the distribution networks. Electric vehicle charge points, heat pumps and storage batteries can sometimes mean higher loads at the low-voltage level and can also be expected to consume electricity at the same time. However, network operators frequently have the possibility of controlling electric vehicles, heat pumps or storage batteries without this having a detrimental effect on their intended use by consumers.
Section 14a of the German Energy Industry Act (EnWG) gives the Bundesnetzagentur the power to issue determinations with uniform national arrangements. On 23 November 2023 the Bundesnetzagentur laid down provisions on network tariffs for controllable connections and consumer devices.
Modules 1 and 2, which took effect on 1 January 2024, provide for operators of controllable consumer devices to receive a reduction on network tariffs in return for allowing their devices to be controlled.
In addition, module 3, which took effect on 1 April 2025, introduced a time-variable network tariff with three different tariff levels. The aim here is to give consumers an incentive to shift their consumption to times when demand is lower. This is relevant in particular to charging electric vehicles. It enables consumers to save network tariffs and reduces the load on the network. At the time the ruling chamber issued the determination, the obligated network operators had a period of one year and four months to implement module 3. In the Bundesnetzagentur’s view, it is unacceptable that consumers are not able to benefit from time-variable network tariffs under module 3 because their network operators have failed to implement the arrangements.