Germany is entering a decisive phase in the reform of its electricity network tariff system. With growing pressure to make grid charges more efficient, transparent and system-oriented, the German regulator, Bundesnetzagentur (BNetzA), is reviewing how network tariffs should be structured in the future.
What are network tariffs and why do they matter for BESS?
Network tariffs are fees paid by electricity consumers (e.g. private households, commercial industrial consumers) for using the electricity grid. For battery storage (BESS), these tariffs directly affect operating costs and, by extension, the business case for a project. BESS have a “double role” in this case as they act as consumer, when charging from the grid, but also as a generator when feeding into it. Currently, BESS in Germany are exempt from paying network tariffs, which has been a key pillar of the investment case for many projects built in recent years.
What is changing?
The BNetzA is using the AgNes process to review whether the existing tariff structure, including the exemption for storage, is fit for the future. The core idea is to move from a static tariff system toward dynamic network tariffs: price signals that reflect actual grid congestion and give flexibility providers like batteries an incentive to behave in a grid-beneficial way.
What makes this reform especially important for storage is that the BNetzA is no longer looking only at how tariffs should become more dynamic. It is also raising the question of whether the current storage exemption from paying grid tariffs, currently valid for projects coming online until August 2028, should remain in place, even for projects that have already received the exemption and built their business case on it.
How would dynamic tariffs work?
The BNetzA’s concept distinguishes between a financing charge and an incentive charge. The financing charge is intended to contribute to network cost recovery. The incentive charge is designed to steer behavior by rewarding or penalizing operation depending on network congestion. Under this framework, storage would no longer be treated through a broad exemption, but through a tariff system that combines cost recovery with more active operational signals. The proposal includes an option under which BESS could earn more through the incentive charge than they pay via the financing charge, thereby rewarding assets that help relieve grid congestion and penalizing those that do not operate in a grid-friendly manner.
Our recommendations to the BNetzA
On 27 February 2026, we submitted our consultation responses on two papers published by the BNetzA. This concerned their papers on Dynamic Network Tariffs and Storage Network Tariffs, published under the ongoing reform of electricity network tariffs - “AgNes”. The consultations are expected to lead to a final decision by the end of 2026, with implementation anticipated in 2029.
In short, we believe the following is essential for the reform to work in practice:
- Provide clarity now on the future of the grid fee exemption for BESS to preserve investability: The current uncertainty is undermining investment confidence. The BNetzA should set out clear transition rules for existing projects as soon as possible. If the exemption for existing BESS is to be phased out, the replacement regime must deliver measurable improvements in system outcomes while preserving a workable investment case for batteries. The legitimate expectations of existing projects should not categorically be called into question. If the incentives are well designed and work in practice, we expect operators to migrate voluntarily.
- Ensure that dynamic tariffs create meaningful operational incentives: Dynamic tariffs should only replace the current exemption if they reflect actual network conditions and create meaningful incentives for grid-beneficial behaviour. Their purpose should be to improve system outcomes, not simply to add a new cost layer for storage.
- Use dynamic tariffs to replace existing restrictions, not add to them: BESS already operate under a patchwork of constraints imposed by different grid operators. These vary widely and often lack transparency. Dynamic tariffs should replace this fragmented system with a single, clear market-based steering logic. Additional restrictions on top should be the exception, not the rule.
- Align cost allocation with system value, rather than shifting it disproportionately onto battery storage: The costs and investments needed for a modern, flexibility-enabled grid should be borne across the system, rather than being shifted disproportionately onto battery storage assets that provide that flexibility.
- Set binding standards for grid operators and prioritize a credible transition path: Minimum requirements for how signals are published, how frequently they are updated, and how they are settled must be standardized across all grid operators. Without this, dynamic tariffs risk creating additional complexity rather than resolving it. At the same time, the new tariff regime does not need to be fully implemented in every detail by 2029. What matters is a clear transition path, binding milestones, and disciplined delivery. Otherwise, there is a risk that a short-term, suboptimal compromise becomes a permanent solution.
