The future of electricity network charges in Germany is presently under intense discussion. The country’s electricity regulator, the Bundesnetzagentur, published a discussion paper on its general electricity framework determination (Festlegung der allgemeinen Netzentgeltsystematik Strom, “AgNes”) on 24 September 2025. This is a further milestone in the process of reform. Current rules are coming under increasing pressure, in particular the various special network charges for industrial customers. The Bundesnetzagentur has set itself the goal of improving the framework’s transparency and fairness, and restructuring it to meet the challenges of the energy transition.
A large number of industrial enterprises in Germany currently profit from reduced network charges. Special provisions (such as the “high-demand privilege” (Bandlastprivileg) or compensation paid to generators when network charges are bypassed (vermiedene Netzentgelte)) grant such enterprises significant relief, the frequent argument being that their actions benefit the network or help stabilise it through steady demand. These privileges add up to several billion euros a year and mean that small and medium-sized electricity consumers finance the network disproportionately.
AgNes, the new general electricity framework
The AgNes proceedings are aimed at completely restructuring this system. One of the Bundesnetzagentur’s proposals is that generators pay a share of network costs, for example in the form of charges dependent on feed-in or a basic network charge to be paid by all network users. Another option on the table is to augment classic charges based on supply or output with components based on capacity or time of use. The idea is to make future network charges also reflect when and how network resources are used, contingent on market fluctuations or bottlenecks. This is a paradigm shift with far-reaching consequences for industry, business and energy providers alike. It represents a gradual loss of privileges for high-consumption industrial enterprises, which have historically enjoyed stable and in many cases discounted charges.
The Bundesnetzagentur has adopted a cautious tone, but the direction is clear: network charges are to be redistributed according to current and future network load. This also applies to compensation for “atypical network use” (when major consumers reduce consumption during peak demand) as well as to compensation paid to generators when network charges are bypassed, which is to be gradually abolished from 2026 to 2028. Companies that have thus far benefitted from network charge reductions will need to adapt to these changes.
Another point for discussion in the AgNes proceedings is the integration of storage facilities into the general electricity framework. The Bundesnetzagentur is signalling that the storage industry should prepare for network charges to take effect no later than August 2029. The same applies to the inclusion of generators in the framework. Here too, the Bundesnetzagentur has indicated the possibility of network charges for electricity feed-in. This would primarily impact renewable energy installations, which would then become part of the network charge system.
In an increasingly volatile electricity system, the overall aim is to reward flexibility, for example by reducing charges in periods or regions of low network strength, using targeted price signals to do so. For this to happen, however, the entire metering and grid management infrastructure will need to be modernised in order to incentivise the use of remote meters.
The consultation phase: initial reactions from industry
The public consultation phase, during which companies, trade associations and network operators can comment on the current draft, will last until 21 October 2025.
A cross-industry workshop on industrial network charges was also held on 30 September 2025. Reactions to the proposed reforms were mixed. The majority of respondents rejected the proposal that generators share in network charges. There was greater openness to a one-off grid connection contribution. Respondents were positive about a capacity price, recognising it as a market-driven scarcity signal that would help make network charges more flexible, as envisaged. The integration of storage facilities was also welcomed across the board. But most respondents were critical of both the proposed basic network charge for all users and the harmonisation of charges across Germany, citing a lack of incentives to meet the needs of the system and potential uncertainties as to the responsibility of network operators. Nevertheless, some also recognised the proposed harmonisation as an opportunity for companies with interests across the entire country, and for removing disparities. There was broad support for dynamic charges, as these might incentivise consumers to act to the network’s benefit. But it was cautioned that such charges must be introduced gradually and would entail new technical requirements. Industry representatives also noted that for operational reasons they are often unable to react to capacity-based or dynamic charges with the requisite flexibility. Should dynamic charges be introduced, this factor would need to be taken into account to avoid systematically handicapping industry.
The results of the consultation will be incorporated into the next draft of the AgNes determination, to be finalised by the end of 2026 as things stand. The current rules laid down in the Electricity Grid Charges Ordinance (Stromnetzentgeltverordnung) are due to expire at the end of 2028 and will be replaced by AgNes, though transitional provisions are envisaged.
Outlook
We recommend that energy-intensive companies, in particular, keep a close eye on developments, analyse potential cost impact early on, and actively contribute to the consultation process. This also applies to storage developers and operators of renewable energy installations; here too, there are signs that companies may face network charges in future.
In any event, the future network charge system will be dynamic and flexible. But even if a radical change to existing special network charges is imminent, the Bundesnetzagentur has committed itself to protecting existing agreements. So today’s special charges may live on past 2028 – even as the new system is introduced in parallel – to avoid putting energy-intensive companies at a disadvantage and precipitating breaches of contract.
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