Smart metering systems are playing an increasingly important role in the energy transition. With the amendment to the Metering Point Operation Act (Messstellenbetriebsgesetz, “MsbG”) in early 2025 binding installation targets for smart meters have now been introduced. However, current data indicates that default metering point operators may struggle to meet these targets for 2026. In addition, there is a growing concern among stakeholders that distribution system operators may regain a monopoly on metering point operation.
Smart meter rollout: Research and monitoring
Although efforts to deploy smart meters are ongoing, the speed of implementation continues to lag behind statutory targets. According to monitoring data from the Federal Network Agency (Bundesnetzagentur), a total of 1,607,202 smart meters had been installed as of 30 June 2025. 760,000 of these are mandatory installations that count towards the required target. This means that only around 16.4% of the legally required meters have actually been installed, with smart meters representing only around 3% of the total of such meters. According to the MsbG, more than 90% of all metering points must have a smart meter and associated gateway by 2032. The MsbG also contains ambitious short-term targets: By the end of 2025, a 20% rollout quota must be achieved for end consumers with controllable consumption devices (e.g. heat pumps, wall boxes) and those with an annual electricity consumption of between 6,000 and 100,000 kilowatt hours. The next targets must be met by the end of 2026; target quotas will also apply to generating installations up to 100 kilowatts.
A technical study published by the Horizonte Group in November 2025 entitled “Technische Studie 2.0 – Steuern in der Niederspannung” (Technical Study 2.0 – Low Voltage Controls) addressed the question of whether distribution system operators and default metering point operators are capable of meeting these statutory rollout obligations. The study concluded that launching the mass rollout of smart meters for new systems in 2026 – as required by the MsbG – will not be possible, primarily due to technical constraints. The authors recommend a twelve-month extension, proposing that the next set of rollout deadlines be postponed from the end of 2026 to the end of 2027. They also recommend changing the legal requirements: The smart meter rollout should take account of the differences between grids, especially in urban and rural environments. The study therefore calls for a more “grid-based” approach as opposed to a full-scale national rollout.
The Energy Transition” Monitoring Report published in September 2025 by the Institute of Energy Economics at the University of Cologne, which was commissioned by the Federal Ministry for Economic Affairs and Energy (Bundesministerium für Wirtschaft und Energie), also concludes that the rollout target is unlikely to be met by the end of 2026. While the monitoring report – unlike the Horizonte Group’s study – assumes that rolling out smart meters across Germany is generally technically feasible, it identifies outstanding legal issues and uncertainties, such as the potential obligation to provide a blackout-proof connection or changes to market communication that may be required in future. In order to meet the statutory target of 90% of mandatory installations in 2026, the report calls for a stricter sanctions regime for metering point operators that fail to comply with the statutory installation obligations. It also suggests creating positive incentives for metering point operators and promoting cooperation through regulation, with the aim of ensuring that defined minimum targets can be exceeded.
Ministry’s ten-point plan
Drawing on the “Energy Transition” Monitoring Report, the Federal Ministry for Economic Affairs and Energy has unveiled a ten-point plan that reaffirms its commitment to accelerating the smart meter rollout. One of the plan’s proposals is to shift the responsibility for mandatory rollout to distribution system operators.
Even under the current framework, only default metering point operators – typically the distribution system operators – are legally bound by the MsbG’s rollout targets. The ten point plan’s wording has therefore caused confusion among independent metering point operators. Industry commentators fear that this could mark the end of competition and lead to the default metering point operators regaining a monopoly on metering point operation. They point out that while the default metering point operators have been struggling to meet all their statutory rollout obligations, competing metering point operators have helped achieve the targets. It remains unclear how the statement in the Ministry’s plan is to be understood. A minor inquiry by the Green Party in the German parliament (Bundestag) on this issue elicited only a vague response, which mentioned both strengthening the inherent incentives for distribution system operators and the importance of cooperation and support during the rollout.
The ongoing uncertainty has recently prompted leading market players to issue a joint appeal calling for a clear commitment to competing metering point operation. The Ministry is expected to issue a statement in early 2026, which should provide more clarity on the future organisation of the rollout.
Amendment to the MsbG
In a September 2025 position paper, a number of competing metering point operators stated their key concerns in connection with the current proposed amendment to the MsbG. However, the Act to Amend Energy Industry Law to Strengthen Energy Consumer Protection and Amend Further Provisions of Energy Law (Gesetz zur Änderung des Energiewirtschaftsrechts zur Stärkung des Verbraucherschutzes im Energiebereich sowie zur Änderung weiterer energierechtlicher Vorschriften) (Bundestag document 21/1497) passed by the German parliament on 21 November 2025 failed to address the concerns expressed in the position paper. The key proposed amendments are as follows:
- The new section 5(1), sentence 2 MsbG (draft) restricts grid connection users from switching to a competing metering point operator for a period of two years if a metering point was initially set up by a default metering point operator. The proposed lock-in period aims to prevent the removal and subsequent disposal of smart metering systems shortly after their installation due to a change in operators. The ultimate goal of the provision is to reduce electronic waste. However, competing metering point operators argue that the lock-in period restricts competition by limiting end consumers’ right to choose.
- Pursuant to section 41(1), sentence 2 MsbG (draft), default metering point operators will have the option of cooperating with other default metering point operators to meet their statutory rollout obligations. Under current legislation, smart meters only count towards statutory rollout targets if they are installed in a default metering point operator’s own grid area. This allows default metering point operators to aggregate and share rollout targets across the entire area they are cooperating in, giving them added flexibility in meeting these targets. The rule has generally been welcomed, but competing metering point operators have urged that the MsbG should be expanded to facilitate cooperation between default and competing metering point operators, too.
- The draft amendment also proposes changes to how grid connection users are provided with information on their energy use. Any information on energy use that grid connection users can generally access at any time (pursuant to existing section 61(1) MsbG) must be available within 15 minutes, according to section 61(2), sentence 2 MsbG (draft). The current legal timeframe is 24 hours. This provision has sparked criticism, with critics saying that mandatory provision of real-time, 15-minute interval data increases IT costs and ties up significant resources. With many metering point operators still busy implementing existing requirements requirements, there are concerns that the additional requirements could significantly delay smart meter rollout.
The German parliament has also passed a resolution calling for further changes required to advance the rollout. The resolution calls for the next MsbG amendment to include tougher sanctions for default metering point operators who fail to meet their obligations. The Federal Network Agency is already able to take regulatory action under section 76 MsbG, but few sanctions have been imposed to date. This is why mandatory remedies have been proposed for cases where default metering point operators fail to meet statutory rollout targets. Such remedies include obligatory transfer of default metering to a fallback operator and compulsory tendering of the role of default metering point operator. The resolution also calls on the Federal Government to explore further strategies for accelerating and scaling smart meter rollout, going beyond the recommendations made in the “Energy Transition” Monitoring Report.
Standardised contractual terms for operating metering points
There has also been movement from the Federal Network Agency. The Federal Network Agency has published new standards for metering point operations and, for the first time, standard model contracts for grid connection users and suppliers. Amendments to the existing standard metering point operator framework agreement between metering point operators and distribution system operators (“MSB-RV”) will take effect on 1 July 2026. The metering point agreements between default metering point operators and grid connection users (“MSV-AN”) and between default metering point operators and energy suppliers (“MSV-LF”) have now also been standardised. There had previously only been non-binding model contracts for these contracts; metering point operators were permitted to set their own terms and conditions. It will be mandatory to use the new model contracts from 1 July 2026. Existing contracts must be amended accordingly.
The MSB-RV governs metering point operations of metering point operators and distribution system operators which are different entities and must therefore be concluded between any competing metering point operator and the distribution system operator in each area in which the competing metering point operator wishes to operate. The now standardised MSV-AN and MSV-LF, however, apply only to default metering point operators. Competing metering point operators also remain free to conclude their own contracts with grid connection users and energy suppliers.
The new MSB-RV contains binding contractual penalties for the first time. If a contracting partner (distribution system operator or metering point operator) breaches material contractual obligations – such as missing meter readings, failure to meet deadlines during the switching process or failure to transmit master data – a contractual penalty of ten cents per day and metering point will apply. Competing metering point operators have expressed strong opposition to such penalties in the past, fearing that they will be primarily affected by contractual penalties given that the default metering point operator is generally also the distribution system operator.
The Federal Network Agency is also introducing a standardised form pursuant to section 54 MsbG. This form is a mandatory part of any contractual arrangements that trigger data communications through or with the aid of the smart meter gateway. In particular, the newly standardised form must contain information on who receives what data from whom, how often and for what purpose. This requirement has been introduced to improve consumer protection.
Conclusion and outlook
The developments in recent months show that even though there is widespread consensus that the smart meter rollout is a key pillar of the energy transition, the metering landscape remains highly volatile. Further amendments to the MsbG and related legislation are therefore likely. This dynamic environment is largely attributable to the complex and multi-layered market structure, in which several stakeholders – including the Federal Ministry for Economic Affairs and Energy, the The Federal Network Agency and the Federal Office for Information Security (Bundesamt für Sicherheit in der Informationstechnik) – define the regulatory framework. Navigating this complexity is further compounded by unresolved technical challenges across the industry.
The Federal Ministry for Economic Affairs and Energy’s upcoming statement on the current debate about the future role of independent metering point operators is likely to attract widespread attention. It remains to be seen, however, whether the Ministry will dispel concerns about a re-monopolisation of metering point operation and whether competition in the sector will ultimately be strengthened or weakened.
Forward
