New award procedure for transmission grid connections – “maturity model” to replace first-come, first-served

The four transmission system operators 50Hertz, Amprion, TenneT and TransnetBW have proposed a maturity-based procedure for awarding connections to the transmission grid. The procedure is to replace the current first-come, first-served approach. Applications will be processed in fixed cycles, must meet minimum formal criteria and will be prioritised by project maturity rather than submission date. The first application cycle under the new procedure is scheduled to begin on 1 April 2026.

Legal framework and background

Grid connection reservations have become a critical milestone for project developers across a range of industries, whether for large-scale battery energy storage systems (“BESS”), data centres or electrolysers. The general legal basis for handling connection requests is section 17 Energy Industry Act (Energiewirtschaftsgesetz, “EnWG”), which requires grid operators to facilitate connection to their grid in a reasonable, non-discriminatory and transparent manner.

In recent years, the number of connection requests has risen significantly, especially for BESS. The current first-come, first-served system allows projects to secure connection reservations at an early stage – sometimes even when unlikely to proceed – thereby blocking capacities for projects close to realisation. This approach has now reached its limits. According to the transmission system operators (“TSOs”), almost all available transmission grid connection points for the next five years have already been allocated, and in some cases secondary markets for trading in reservations have emerged. The surge in applications also outstrips both the TSOs’ capacity to process them and the electricity demand identified in the grid development plan.

The TSOs have therefore proposed the introduction of a maturity-based (“first-ready, first-served”) procedure. This method, which has already proven effective in the UK, Norway and France, is intended to ensure that the energy transition is implemented efficiently and in line with actual grid needs.

Key elements of the maturity-based 

• Scope: The new procedure will apply to consumer connections and BESS installations, for which no statutory procedure currently exists beyond section 17 EnWG. Distribution system operators will also be affected where large-scale projects on their grids require larger-capacity connections to the transmission grid. Generation plants such as renewable energy installations or conventional power plants of 100 MW or more are not covered and will remain governed by the Renewable Energy Sources Act (Erneuerbare-Energien-Gesetz, “EEG”) or the Power Plant Grid Connection Ordinance (Verordnung zur Regelung des Netzanschlusses von Anlagen zur Erzeugung von elektrischer Energie, “KraftNAV”). Energy storage installations are affected, however, because the amendment to the KraftNAV, which entered into force on 24 December 2025, excludes them from its scope, meaning they remain governed by section 17 EnWG.
• Basic principles: The maturity model is based on three core principles: cyclical processing of applications, compliance with minimum formal criteria and – in the event of oversubscription – prioritisation by project maturity.
• Overview of the procedure: The first cycle is set to start in April 2026 and will consist of three phases:

1. Phase 1 – Information and application phase (three months): Applications can be submitted during this period and a fixed-rate application fee of EUR 50,000 is payable. The TSOs will offer an optional completeness check that can be requested up to six weeks before the phase ends.
2. Phase 2 – Cluster study (five months): This phase includes an eligibility check, maturity assessment, capacity allocation and grid analysis.
3. Phase 3 – Offer phase (two months): Successful applicants will receive a binding grid connection offer, which must be accepted by paying a project implementation security deposit of EUR 1,500 per MW within one month. This deposit will later be offset in full against the construction cost contribution.

• If a project is not considered: Applicants in a given cycle have a right to be considered for existing capacities only. They do not have a claim to the expansion of connection capacity. Projects that are genuinely being developed but cannot be accommodated due to insufficient capacity may be carried over to the next cycle at no extra cost. However, if an application is ruled ineligible in phase 2 due to a failure to meet the minimum requirements, the TSO will return 50% of the application fee.

Cluster study – maturity criteria and assessment

The TSOs’ concept paper focuses on the maturity assessment in phase 2. The assessment uses four equally weighted maturity criteria:

• A – Land availability and permit status: site availability (lease/ownership) and permitting strategy.
• B – Technical concept for installation and connections: project plan, site plan and grid connection line routing strategy.
• C – Economic viability: corporate credentials, component procurement and project financing.
• D – Grid and system utilisation: colocation of various technologies and overbuilding generating capacities.

Each criterion can include further subcriteria. Within this structure, applicants must first fulfil certain minimum eligibility criteria, which the TSOs will check. If, at least theoretically, sufficient capacity is available, meeting these minimum requirements alone will qualify a project for a connection reservation. However, if eligible applications exceed the available capacity, prioritisation will be based on “maturity points”. The assessment relies on the same four criteria and their subcriteria (A1, A2, etc.), with between one and three points awarded per subcriterion, depending on how far the project has progressed.

For instance, under criterion C (economic viability), the minimum requirements are evidence of the company’s existence, an inventory list and quantification of the planned investment volume. Applicants will receive one maturity point if they also provide supplier offers for time-critical components and a credit report. The maximum three points are awarded if purchase contracts for time-critical components have been signed and financing can be demonstrated.

[Find a detailed overview of the maturity criteria and their assessment here.]

• Transitional arrangements for existing applications

The concept paper and the TSOs’ press release confirm that existing grid connection commitments will remain valid and be realised as planned. Applications still pending under the first-come, first-served approach can either be transferred to the maturity-based procedure or withdrawn. Transfer requires the amendment or complete resubmission of the documents. Application fees already paid will be credited in the event of transfer and refunded if the application is withdrawn.

• Assessment and recommended actions

The shift to prioritisation based on project maturity has been anticipated for some time and is, in principle, supported by energy industry associations. However, it remains to be seen whether it will actually be implemented by 1 April 2026. The TSOs themselves assume that this will require a legislative amendment, including approval from the Federal Network Agency (Bundesnetzagentur).

A sound maturity-based procedure can also only succeed if the underlying criteria are non-discriminatory, reasonable and applied in a transparent and objective manner, with the timelines and deadlines under the procedure also being binding on the TSOs. This is the only way to create certainty for project planners.

Companies that currently have a grid connection application lodged with a TSO should first assess what stage the application has reached. Reservations that have already been granted should remain valid. Follow-up projects currently without a reservation will no longer receive one under the old procedure but must instead participate in the maturity-based procedure. Connection applications now under advanced-stage consideration under the first-come, first-served procedure but still awaiting a reservation will require case-by-case legal assessment to determine how far conversion to the new system may potentially and unjustifiably downgrade their status compared to at present.

Companies planning a transmission grid connection in the future should start preparing early. This includes, in particular, compiling technical and economic documentation, securing rights to sites and initiating permit procedures. The necessary funds to pay the fixed-rate application fee (EUR 50,000) and the deposit (EUR 1,500 per MW) should also be earmarked in advance. Companies would also be advised to establish suitable systems for monitoring deadlines and documentation to fully leverage the first application cycle from April 2026 – including the optional completeness check by the TSOs during the initial six-week period.