Public Law

Update: Final framework for Grid Connection "Maturity Model" published

On 1 April 2026, the four transmission system operators 50Hertz, Amprion, TenneT and TransnetBW launched the first application cycle of the “maturity model”. In this connection, they published a revised concept paper setting out the binding maturity criteria and procedural rules for the first application cycle. While the three basic principles of the procedure – cyclical processing, compliance with minimum criteria, and prioritisation based on maturity – remain unchanged, the final procedural documentation contains a number of significant changes and further clarifications. The application cycle started as planned on 1 April 2026, with the deadline for submitting applications expiring on 30 June 2026.

Background

On 5 February 2026, the transmission system operators (“TSOs”) published an initial concept paper proposing that the “first-come, first-served” approach applicable to grid connections under section 17 Energy Industry Act (Energiewirtschaftsgesetz) be replaced by a maturity-based procedure (see our article: New award procedure for transmission grid connections – “maturity model” to replace first-come, first-served. The maturity-based procedure aims to make more efficient use of scarce grid resources in response to the growing demand for grid connections, particularly from large-scale battery energy storage systems. The procedural documentation published on 1 April 2026 now sets out the binding criteria and rules for the first cycle of awarding grid connections under the new procedure. The underlying approach of the maturity-based procedure remains the same as in the concept paper: all grid connection applications received within an application cycle that fulfil the minimum criteria are compared with each other and prioritised based on their maturity.

Timeline

The first application cycle entered the information and application phase on 1 April 2026. During this phase, applicants can submit questions regarding the new procedure to the TSOs and prepare their applications. The phase ends with the application deadline on 30 June 2026. As envisaged in the concept paper, this is followed by a five-month cluster study, during which the applications received are assessed by the TSOs. All applications are expected to have been processed and binding offers issued by the end of this phase, on 30 November 2026. Grid connection applicants will then have one month to accept the offers by paying a project implementation security deposit. Where offers issued by the TSOs are rejected by applicants, other projects may move up for which another one-month period is granted to applicants to decide whether to accept the offers. The first cycle is expected to be completed by February 2027. The framework for future cycles may be adjusted based on practical experience.

Available capacity

Along with publication of the procedural documentation, the TSOs also disclosed the grid connection capacity available for the first application cycle on their respective websites. This information highlights the scarcity of grid capacity: grid connections will only be available from 2029 onwards, and in some regions no grid connection points are available at all. The information published by the individual transmission systems operator varies as follows:

  • 50 Hertz: Eleven grid connection points are available; however, feed-in is not possible at one of these points. Project launches will likely not be possible until 2029. The website also provides information on the expected number of switchgear bays and the maximum available load and generation capacity (in MW).
  • Amprion: Ten grid connection points are expected to be available; however, feed-in will not be possible at two of these points, and a further three will only permit feed-in at reduced capacity. The earliest projected commissioning date is 2032. Information was also published on whether one or more connection bays are expected to be implemented.
  • TenneT: Ten grid connection points are expected to be available; however, feed-in will not be possible at two of these points. The earliest projected commissioning date will be 2030.
  • TransnetBW: Nine grid connection points are expected to be available, all from 2032. Information was also published on the available load and generation capacity (in MW). In addition, six grid connection points with long-term available capacity were identified (available from 2035). It is not clear from the information published whether this capacity is also intended to be included in the first application cycle.

The publications suggest that, in the first application cycle, the TSOs will make available all grid connection capacity that is already in place and will become available over roughly the next ten years. In subsequent application cycles, the grid connection capacity made available is therefore expected to be limited to newly created capacity and capacity released by projects that are not implemented.

Key changes and clarifications

The final procedural documentation introduces several changes compared to the concept paper, which project developers will need to factor in when preparing their applications. 

Revised weighting and reduced points system

The scoring system has been fundamentally revised. The maximum achievable total score has been reduced from 18 to 11 points. At the same time, the originally envisaged equal weighting of all four criteria has been abandoned in favour of differentiated weighting. Under the revised framework, criteria A (land availability and permit status), B (technical concept for installation and connections) and C (economic viability of the applicant) are each assigned a weighting of 30%, while criterion D (network and system benefits) now accounts for only 10% of the total score. The most significant changes affect subcriterion C3 (economic viability). This subcriterion is no longer subject to any minimum requirements, and an additional point can be obtained by providing proof of creditworthiness. This proof may be furnished in the form of ratings from recognised rating agencies, information from specified credit reference agencies, or early payment of the project implementation security deposit. These changes reflect an adjustment of the previously envisaged strict requirements, which would have favoured larger companies in particular, e.g. by requiring the submission of comprehensive project financing evidence.

The specific assessments of the maturity criteria have also been adjusted. A detailed and updated overview is available here.

Differentiated tie-break procedure

While the concept paper merely provided that projects with an identical score would be “treated equally”, the final procedural documentation introduces a detailed tie-break mechanism. In the event of a tie, prioritisation is based on two assessment criteria, applied in the following order:

  1. Waiting time: Priority is given to the application with the earlier receipt date. Within an application cycle, the cut-off date is deemed to be the date of receipt, meaning that all new applications are treated equally. In contrast, the original application date is taken into account for all projects for which a complete application was already filed before 5 February 2026 under the previous procedure. This approach reflects the fact that applications submitted early – but not yet decided – would have had better prospects of obtaining a grid connection under the first-come, first-served approach than applications submitted later.
  2. Site specificity: If no priority can be established on the basis of the waiting time, demand at an existing, site-specific withdrawal point is given priority over other types of demand.
  3. Drawing of lots: If priority cannot be established on the basis of the above criteria, it is determined by drawing lots.

Completeness check removed

The optional completeness check expressly provided for in the concept paper is absent from the final procedural documentation. As a result, applicants must exercise significantly greater care, as the submission of an incomplete application leads to immediate exclusion from the procedure, with only 50% of the fixed application fee of EUR 50,000 refunded.

In the event of exclusion, applicants are informed accordingly and provided with a detailed list of the unmet requirements. With no possibility to supplement or amend applications after submission, project developers should carry out particularly thorough internal quality checks of their application documents prior to the cut-off date.

Expanded grounds for revoking grid connection reservations

The paper also expands the grounds on which an existing grid connection reservation may be revoked by the TSO. In addition to the grounds already known from the concept paper, a reservation may now also be revoked in the event of material changes to the project or the project parameters that would have had such a negative impact on the maturity score originally achieved that the project would not have been granted a reservation in the first place. This introduces a post-grant review mechanism intended to ensure consistency between the assessment of an application and the actual implementation of the project.

Assessment

The final procedural documentation confirms the key elements of the paper presented in February, but introduces selected adjustments. In particular, the revised weighting of the assessment criteria places greater emphasis on project-specific criteria than on the system benefits component. Some of the criticisms raised by grid connection applicants, such as concerns about the preferential treatment of larger companies under the economic viability requirement, have been addressed. One of the main criticisms – insufficient transitional arrangements for advanced but undecided applications under the previous procedure – has been partially addressed by factoring in waiting time in the event of a tie. However, costs already incurred for grid studies are still not taken into account separately.

Given the 30 June 2026 deadline and the fact that late submissions are expressly not permitted, companies planning to participate in the first application cycle should begin compiling their documentation without delay and ensure that sufficient funds are available. The removal of the completeness check significantly increases the preparatory workload for applicants. Preparation of the application documents is further complicated by the fact that the application forms referred to in the procedural documentation have not yet been published.

Driven by the large number of requests for grid connections, the maturity-based procedure was introduced on a fast-track basis. As already outlined in our newsletter of 18 February 2026, the legal basis for the procedure remains unclear. Despite these uncertainties, project developers planning a future transmission grid connection should carefully compile the required application documentation by 30 June 2026, as a substantial share of the transmission grid’s available capacity for the coming decade is expected to be allocated in the first application cycle.

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