2025 has been a year of uncertainty for grid regulations in Germany, and although we still lack clarity on what the reforms and new grid fee structure will entail, there are unmistakable signs that regulators are actively working on solutions in the background.
In September 2025, the German Federal Network Agency (Bundesnetzagentur – BNA) published a discussion paper on industrial grid fees, acknowledging consultations on the subject and proposing new regulatory approaches. Proposed reforms promote a push toward flexibility, potentially with storage in a supportive function. Where the old grid fee structure rewarded inflexibility, the new scheme would incentivize flexibility.
The so-called 7000-hour rule laid out in Section 19(2) StromNEV, often referred to as Bandlastprivileg (band load privilege), is a policy tool in the old design that encourages steady, predictable load behavior in exchange for cost relief. For example, bulk consumers with an annual consumption of over 10 GW receive a grid fee reduction of up to 80 or 90%, depending on their distance to a major power plant. Eligibility required their annual use divided by their annual peak to exceed ≥7,000/8,000 hours, which corresponds to a flat consumption profile without significant peaks. The policy shaped entire industries in Germany, as production sites all over the country built their processes around this rule.
To illustrate this further with an example, energy accounts for 40% of aluminum production costs. Given this budgetary reality, it should come as no surprise that individualized grid fee reductions aren’t just a perk for affected companies but the primary cost factor. The German Association of Industrial Energy Consumers (Verband der Industriellen Energie- und Kraftwirtschaft – VIK) confirmed this in 2024 in a public statement, attributing “enormous economic significance” to individualized grid fees and describing them as a “key location factor."
Historically, individual grid fee regulations in Germany were treated as separate entities:
The policy discourse aims to replace the base load privilege with industry grid fees. Atypik will no longer exist as a separate grid fee reduction and instead fold into the general regulatory framework. As the new system is expected to entail more dynamic elements, a carve-out for atypical network use is considered redundant.
With StromNEV terminating and the energy transition calling for industrial engagement, the German regulator (BNA) proposes three new ideas to flexibilize the industry and justify grid fee reductions in accordance with EU law, emphasizing that grid fee reductions are contingent on reciprocity, meaning the grid must receive a service in return.
Industries have two ways of meeting the flexibility requirement – adapting the production process or deploying BESS (battery energy storage systems). Both options require investments, but for companies that already receive the 80% grid fee reduction, installing storage is an additional cost just to keep the status quo. Without this investment, they would lose the 80% discount and might choose to outsource certain processes or relocate production abroad to ensure continued cost savings. According to Netztransparenz, the projected cost of the grid fee reductions in 2025 is around € 1.4 billion for roughly 560 customer agreements, and it is end consumers who ultimately pay for it. It appears obvious to argue that a sum of this magnitude could meaningfully advance the BESS infrastructure in Germany. The regulatory discourse in Germany is as much about industry policies as it is about tariff policies. Once more, it remains to be seen what exactly will come of the grid fee reforms and how battery storage will be affected.
Do you have a battery in Germany and are concerned about the regulatory impact on your use case?