BESS In Germany: The BNetzA Plans To Introduce Grid Fees For BESS

The German Federal Network Agency (BNetzA) plans to introduce grid fees for stand-alone battery energy storage systems (BESS) in the course of a larger structural reform of electricity grid fees in Germany.

The key features of the envisaged future grid fees for BESS are expected to include: (i) capacity-related fees, (ii) consumption-related fees for non-bidirectionally used electricity (stored but not fed back into the grid), as well as (iii) dynamic fees linked to how grid-friendly the location and operation of the BESS is.

The dynamic fee is designed to possibly reach negative levels in case BESS operation provides grid relief, thus offering financial upside through proactive corresponding BESS optimization.

Timewise, the BNetzA is considering the possibility of introducing the new grid fees for BESS even before the expiry of the currently applicable grid fee exemption under statutory law. Thereby, even BESS projects taking COD before August 4, 2029 could be subjected to grid fees in the future. The expedience and legality of such plans to overrule the existing statutory grid fee exemption are widely contested amongst industry stakeholders and legal observers.

The grid fee reform process—where we are

The BNetzA is currently reforming electricity grid fees in Germany in the AgNes (Allgemeine Netzentgeltsystematik Strom) process. As a result, the BNetzA aims to issue a determination (Festlegung) by mid-2026 that will establish the new grid fee system applicable as from January 1, 2029.

The overall objective of the grid fee redesign is to achieve a cost-efficient electricity grid with appropriate incentives for grid-friendly location and operation of generation-, storage-, and consumer facilities, and where grid-related costs are fairly allocated to the grid users causing such costs.

On January 16, 2026, the BNetzA published a discussion paper outlining its considerations on the introduction of grid fees for BESS (The Discussion Paper). On January 30, 2026, the BNetzA held a workshop with industry stakeholders on this matter. In an ongoing industry consultation, the BNetzA invites stakeholders to submit their comments until February 27, 2026.

The BNetzA'S planned grid fees for BESS

Under the currently applicable regime, BESS reaching COD before August 4, 2029 are fully exempted from grid fees for 20 years (i.e., until at the latest August 4, 2049) pursuant to section 118 para. 6 EnWG.

The BNetzA's general concept of reformed grid fees foresees a two-pillar design with grid fee components for financing the grid on the one hand, as well as a component for incentivizing grid-friendly usage on the other hand. For BESS, the BNetzA intends to slightly modify this concept to accommodate BESS characteristics and to avoid disincentivizing investment in BESS or inefficient BESS operation.

The grid fee components related to financing the grid shall consist of two elements. Firstly, consumption fees (Arbeitspreis), which shall only be applicable to non-bidirectionally used electricity, i.e., only to the electricity lost during the BESS facility's storage and feed-in process (netting of electricity volumes). Secondly, capacity fees (Kapazitätspreis) based on the amount of “reserved capacity” ordered by the BESS owner as network user (mirroring the capacity-based remuneration system of gas transmission pipeline usage to some degree).

The fee component incentivizing grid-friendly usage shall consist of dynamic (time- and location-wise) fees that would increase in times of high load factors and local bottlenecks (grid congestion) and decrease (possibly to a negative level) in times of low load factors. For this purpose, the local redispatch situation as well as the marginal costs of avoided redispatch measures may be taken into account. Negative grid fees (i.e., receivables for the BESS project) are possible and shall serve as a monetary incentive for location and operation of the BESS in a grid-friendly manner.

Possible retroactive introduction of grid fees

The BNetzA expressed that it is considering introducing grid fees for BESS even before the expiry of the currently applicable grid fee exemption for BESS projects, i.e., also to BESS that reach COD before August 4, 2029. However, the BNetzA did not articulate concrete plans in this regard or indicate specific timelines as to from when it may apply grid fees for such BESS projects.

The BNetzA acknowledged that such measure would have a retroactive effect on all BESS projects that have already been invested in reliance on the stable continuance of the currently applicable legal framework including the availability of the grid fee exemption for the entire 20 years post COD.

How the industry is reacting

BESS industry reactions on the BNetzA plans are mixed. Dynamic grid fee components incentivizing grid-friendly operation enjoy broad support and are viewed as facilitating the energy transition as well as supporting BESS as the providers of grid-friendly flexibility.

Capacity-based grid fee components are viewed as critical for the BESS investment case in Germany depending on the level at which they shall be set.

The potential early introduction of grid fees contrary to the currently applicable grid fee exemption is sharply criticized and its lawfulness doubted considering legitimate expectations of project owners and investors having based their business plan on the currently applicable legal framework.

Selected focus points for investors and BESS project owners

• BESS location risks: obtain local grid congestion and redispatch data to check whether the BESS project's grid area allows for sufficient optimization.
• Financial resilience: check the sensitivity of financial KPIs to different scenarios of future grid fees and whether negative consequences might be triggered under financing agreements.
• Allocation of grid fee related risks: check how the risk of future grid fees is reflected and allocated in project agreements, particularly offtake agreements.
• Potential for operational optimization: check to what extent the operator and marketers are contractually and technically able to optimize the BESS for dynamic grid fees.

Outlook

The BNetzA's reveal of considerations but the lack of definitive decisions on future grid fees for BESS triggers quite some uncertainty for booming BESS investments in Germany, particularly for business cases that have been based on the grid fees exemption until August 4, 2029.

Whether the contemplated future grid fees for BESS will have a material negative impact on BESS business cases will largely depend on the concrete design of the announced grid fee components and the amount of financial upside to be gained via the dynamic grid fee component.

We expect further discussion to evolve around the introduction of grid fees for BESS as the AgNes process progresses, and we will continue to monitor developments closely.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.