Germany’s AgNes draft has set a qualifying FID cutoff for storage projects that seek to retain grid fee exemptions
The proposed FID criteria require binding orders covering at least 50% of investment, raising concerns over the tight deadline
The draft also proposes dynamic storage charges from 2030 and higher prosumer surcharges from 2029
Germany’s proposed new grid fee framework could make electricity storage charges more predictable from 2029, but the industry has raised concerns over the tight deadline to preserve exemptions for existing projects.
As per the draft General Network Charges System for Electricity (AgNes) published by the Federal Network Agency (Bundesnetzagentur or BNetzA) on August 6, 2026, electricity storage projects will remain eligible for the existing exemption from grid fees, for up to 20 years, if they made a qualifying Final Investment Decision (FID) before the agency announces the final AgNes determination, currently planned for the end of 2026. Operators must provide evidence of the FID to the responsible grid operator by March 31, 2027.
To qualify as an FID, a project must have binding orders for components covering at least 50% of the investment volume. The developer should be able to prove that a termination of the contracts would result in a significant financial loss. A loss of at least 25% of the investment is considered sufficient to meet this condition.
Projects that have not made a qualifying FID before the final determination is announced will not receive this transitional protection, even if they could otherwise meet the statutory August 4, 2029, commissioning deadline. Such projects would instead be subject to the new network tariff system from January 1, 2029.
Germany’s current electricity grid fee system is largely based on rules from 2005. BNetzA argues that, on the one hand, grid and congestion costs are rising, and limited grid capacity is also struggling with variable electricity generation, necessitating a new approach. The reform is also required following an EU court ruling, with the current rules expiring on December 31, 2028.
Germany’s grid charges total about €37 billion a year and account for roughly 30% of household electricity costs. The new system, according to the agency, aims to distribute these costs more fairly while reducing redispatch and network expansion costs through incentives for grid-friendly behavior.
The draft also provides for dynamic grid charges for electricity storage, to be implemented by January 1, 2033, but not before January 1, 2030. The charges will change depending on the time and location of grid use. It will be designed to provide price signals to storage operators to use the grid when it is less congested.
While the German industry stakeholders are receptive to the proposed changes under AgNes, the FID requirement timeline has emerged as a cause of concern.
Urban Windelen, the Managing Director of the German Energy Storage Systems Association (BVES), explains that even as the binding deadline provides greater clarity in principle, the short window will complicate the implementation of many projects.
“The past few months have already caused considerable uncertainty and delayed investment decisions. Now companies need legally sound and practical criteria,” said Windelen.
Lars Stephan, Director Marketing, Policy and Public Affairs (EMEA), also believes that while the rules are now clearer for storage projects to secure grid fee exemption, these have been made harder to meet. He believes that developers will need binding contracts covering at least 50% of the investment volume, which could include major components such as the DC block.
“To me it is very clear, that FID by the end of the year is required. Anyone who thinks otherwise can lawyer up and fight it in the courts, but the regulators rational on this appears solid,” stated Stephan in a LinkedIn post.
Legal experts at Raue Law Firm in Berlin highlight one positive ruling included in the definition of FID: BNetzA has done away with the additional requirement of a binding grid connection commitment that was previously included in the interim report.
“This eliminates a significant bottleneck, particularly for battery storage projects at the transmission grid level, which can expect binding commitments in the new maturity assessment procedure no earlier than the beginning of 2027,” stress Raue energy law experts Dr. Hans Heller and Dr. Peter Roegele.
BVES also calls for improvement to the prosumer surcharge as proposed in the BNetzA draft. The AgNes draft proposes a 70% to 90% surcharge on the fixed grid charge for prosumers from 2029. The agency justifies the measure, saying it intends to ensure a more cost-reflective contribution to grid costs. Customers with storage behind the same connection would still be classified as prosumers, while plug-in solar systems are excluded from this definition.
However, BVES emphasizes that prosumers make a significant contribution to the flexibility of the energy system through self-consumption, storage, and grid-friendly behavior. “Additional burdens must not hinder this development,” according to the association.
Under the draft, BNetzA has also proposed an electricity feed-in tariff for existing power generation plants with installed capacity of over 30 kW, linked to their grid connection capacity. It will need to be paid to the distribution grid operator. Transmission system operators will publish the tariff level annually, by October 15, for the following year.
The German Association of Energy and Water Industries (BDEW) largely welcomed the draft proposals, while issuing a caution regarding their implementation. It stressed that the industry needs enough time and clear rules to implement the new system by January 1, 2029. The reform will require major changes to billing, IT systems, market communication, and back-end processes. It therefore urged regulators to avoid adding further requirements before implementation.
Earlier, the German Solar Association (BSW-Solar) had raised concerns about the proposed grid changes under AgNes (see Solar, Storage Stakeholders Differ On Germany’s Grid Overhaul).
Released on August 6, 2026, the draft is open for consultation until September 18, 2026, on the BNetzA website. A final decision is expected by the end of 2026, while the new framework will come into effect from January 1, 2029.
Germany is also set to replace permanent feed-in tariffs with direct marketing for new renewable energy projects as it amends the Renewable Energy Sources Act (EEG) (see German Cabinet Backs Ending FITs For New Rooftop Solar Under EEG).
