Political engagement

The fundamental transformation of the energy system is leading to frequent discussions about adjustments to the electricity market design. In this context, the German federal government has announced the introduction of a capacity mechanism, which is to be conceptualized in 2027. Starting in 2032, this capacity mechanism is intended to provide sufficient dispatchable capacity. However, the federal government has not yet commented on the specific design of this capacity mechanism. EnBW advocates for the introduction of a centralized capacity mechanism. Based on European precedents, such a mechanism would be easier and faster to introduce and easier to adjust over time.

At the European level, reforms of the electricity market, including support mechanisms for renewable energy, are planned for 2026 and 2027.

During the most recent European electricity market reform, EnBW supported maintaining the existing, highly efficient market framework based on marginal-cost pricing and advised against abolishing or significantly changing this framework. EnBW also maintains this position with regard to the upcoming reforms. From EnBW’s perspective, the forthcoming reforms require only minor optimizations and adjustments, as the current market design proved to be resilient to wether an energy crisis as significant as the one following the start of the war in Ukraine.

As part of the so-called power plant strategy, the German federal government intends to meet the need for secured capacity - driven in part by the nuclear and coal phase-outs - by tendering gas-fired and hydrogen-fired power plants. For 2026, the federal government has announced the adoption of the “Act to Safeguard Electricity Supply Security and Provide New Capacity.” Among other things, the act provides for two auction rounds in 2026 to tender a total of 9 GW of long-term capacity; in 2027, an additional 2 GW of generation capacity is to be tendered. In addition, the act provides for a regional component aiming to incentivize the construction of hydrogen-ready gas-fired power plants, especially in the so-called grid-critical southern regions. This is essential for reasons of system stability.

EnBW welcomes the regional component and the federal government’s intention to implement the power plant strategy in 2026. EnBW plans to participate in the auctions. The scope of its participation will depend on the final legislation and the actual auction design.

The energy transition can only succeed through the rapid and reliable expansion of decentralized renewable energy - essentially onshore wind and ground-mounted photovoltaic systems. To achieve this, project developers and investors require planning certainty: the state-aid approval of the current EEG support framework expires at the end of 2026, meaning that an EEG that has been adopted and approved by the European Commission must be in place by January 1, 2027. From EnBW’s perspective, the new investment framework should be based on two-sided contracts for difference (CfDs) - preferably with a market-value corridor that supports market integration and system-friendly operation. At the same time, permitting procedures must continue to be shortened, and practical, balanced solutions must be found for synchronizing generation and grid expansion without disproportionately slowing the expansion of renewables. It is also crucial that the legislative procedures - including the EEG, EnWG, Offshore Wind Energy Act, and the so-called grid package - are effectively coordinated. EnBW is contributing constructively to the ongoing procedures and consultations in order to secure a stable, implementable framework for further expansion.

With regard to onshore wind, several important regulatory improvements were made between 2022 and 2024, such as the new Wind Energy Area Requirements Act (WindBG), the establishment of the overriding public interest in renewable energy in the EEG, the amendment to the Federal Nature Conservation Act (BNatSchG), and the major amendment to the Federal Immission Control Act (BImSchG).

Nevertheless, further measures are required in order to achieve the expansion targets for onshore wind:

• As part of the amendment to the Federal Nature Conservation Act, the rules governing the collision risk for birds of prey were at least standardized nationwide. Unfortunately, the amendment did not regulate requirements for bat protection or the prohibition of disturbance for protected species (in the case of wind turbines, usually noise). Nationwide uniform requirements would also be necessary for these issues.
• To genuinely assess the operational risk of killing birds of prey, a scientifically sound method for evaluating collision risk is required. The first method that is truly suitable for this purpose would be probability calculation. A clear threshold must also be defined to determine when a significantly increased collision risk exists. It must be taken into account that birds of prey are exposed to general life risks even without wind turbines, such as predators, poisoning, road traffic, power lines, etc.
• Until a Federal Administrative Court ruling in 2024, the impairment of the landscape caused by wind energy projects was offset through a compensation payment. Since the ruling, physical compensation measures are to be prioritized. In some federal states, authorities now allow compensation payments only if the project developer proves that no land for real measures is available in the entire district. This is hardly feasible in practice. It would be sensible to give project developers a choice between compensation payments and real compensation measures. The calculation of the amount of compensation should be regulated uniformly nationwide.
• Better staffing and technical resources for planning and permitting authorities.

The most recent offshore wind tenders did not receive successful bids. This shows that the framework conditions have changed noticeably, particularly due to price increases throughout the entire supply chain. To address this, the Offshore Wind Energy Act must be adapted swiftly to the new circumstances. From EnBW’s perspective, this requires a robust auction design that once again enables reliable investment, including two-sided CfDs with appropriate indexation. Implementation of the Net-Zero Industry Act can take place with the help of qualitative criteria. These criteria must be measurable, genuinely support the objective of resilience, and must not be designed in an unnecessarily complex way, so as to limit bureaucracy and documentation obligations to a minimum. Overall, urgent action is needed to avoid a “disruption” and to secure the attractiveness of the German offshore wind market in international competition.

We support the coal phase-out adopted by the German federal government. EnBW itself plans to phase out coal by 2028. However, the necessary prerequisites must be created, including with regard to maintaining dispatchable capacity and implementing the power plant strategy.

To contribute to maintaining dispatchable capacity, EnBW is building and operating so-called fuel-switch plants at various hard-coal sites (Heilbronn, Altbach-Deizisau, Stuttgart-Münster). Fuel switching initially means switching from coal to more climate-friendly natural gas until sufficient hydrogen is available. This makes it possible to immediately reduce CO₂ emissions while also ensuring security of supply by maintaining secured capacity. Fuel switching also makes a significant contribution to preserving sites and jobs. However, the provision of hydrogen must be accelerated in order to implement these projects.

EnBW is implementing the politically stipulated phase-out of nuclear energy in Germany. Following the phase-out decisions of 2002 and 2011, EnBW developed a long-term strategy for dismantling its nuclear power plants and has consistently implemented it ever since. Even though delays compared with the original planning are likely, EnBW currently continues to assume in its assessment that the dismantling of GKN II under nuclear law will take approximately 10 to 15 years. EnBW opposes any further delays in dismantling its nuclear power plants that are politically or regulatorily motivated. From EnBW’s perspective, the construction of new nuclear power plants in Germany, including small modular reactors (SMRs), is not an option.

After initial optimism, the hydrogen ramp-up has slowed down. Investment-promoting framework conditions are needed to enable the hydrogen market ramp-up. The objective is the competitiveness and economic viability of hydrogen solutions - which can only be achieved through scaling and broad market penetration. Three pillars are decisive:

1. Incentivize market-based H₂ demand
   Incentivizing instruments, especially for industry, to bridge the gap between costs and willingness to pay for H₂, such as carbon contracts for difference, are needed. The objective is to make H₂ solutions economically viable and to enable business cases for customers.
2. Create a broad and competitive H₂ supply
   During the H₂ market ramp-up phase, hydrogen will be a scarce commodity. Requirements for H₂ production, especially with regard to electricity procurement criteria, should therefore remain as pragmatic as possible, also with regard to H₂ origin. “Green” H₂ is clearly the long-term objective, but flexibility is crucial, especially in the start-up phase. Low-carbon - essentially “blue” - H₂ will be less expensive than renewable - “green” - H₂ for the foreseeable future and is therefore extremely important for a successful market ramp-up.
3. Develop H₂ infrastructure in a demand-oriented and synchronized way
   Through its subsidiaries Ontras and Terranets BW, EnBW is participating in the development of the H₂ core network. This network is intended to lay the foundation for the ramp-up of the H₂ market. However, the currently planned financing mechanism does not allow for economically viable investments. Concepts for developing H₂ import infrastructure (terminals) and hydrogen storage facilities are also needed.

Security of supply, efficiency, and stability: the requirements placed on our grids are continuously increasing. They must continually adapt to technological change and evolving generation patterns. While Germany aims to become climate-neutral by 2045, Baden-Wuerttemberg already wants to be climate-neutral by 2040. In addition to stronger electrification across all sectors, this also requires the transformation of the gas industry. To achieve this, infrastructure will have to be converted and expanded even faster in the coming years than previously planned. This applies to both electricity and gas infrastructure. EnBW therefore advocates for:

• Planning and permitting processes for grids, generation, and storage to be accelerated and digitalized;
• Grid expansion to be supported through sensible regulatory frameworks and reliable financing;
• The transformation of gas grids to take place with consideration for regional characteristics and in meaningful coordination with local heat planning;
• Grid expansion costs to be reduced by giving overhead line construction priority over underground cabling for new projects at the extra-high-voltage level. For transmission grids, planning ahead is important in order to respond flexibly to actual demand.

EnBW supports the nationwide expansion of digital infrastructure, particularly in the areas of fiber optics and passive mobile communications infrastructure. Lean permitting procedures, comprehensive and unbureaucratic white-spot and gray-spot funding for projects that cannot be implemented economically on their own, especially in rural areas, and the avoidance of overbuilding existing publicly funded fiber-optic infrastructure are decisive for an urgently needed acceleration of the expansion.

Demand-side funding instruments, such as voucher funding for end customers, can make an additional positive contribution to accelerating the expansion of gigabit networks.

The design of the Gigabit Register (Gigabit Grundbuch) should be critically reassessed. While it can provide transparency regarding route alignments and expansion needs, it also increases the vulnerability of critical telecommunications infrastructure. Here, a practicable middle ground must be identified between necessary transparency and ensuring the resilience of telecommunications infrastructure in the current amendment to the Telecommunications Act.

EnBW advocates better shared use of its passive mobile communications infrastructure by mobile network operators. This would make it possible to close mobile coverage gaps in Germany significantly faster.

EnBW is a pioneer in the expansion of fast-charging infrastructure in Germany. A demand-driven and rapid expansion of the charging network can only succeed in a competitive market environment.

The following points are decisive for the successful development of a charging network that meets customer needs:

• Regulatory hurdles must be kept as low as possible.
• It remains necessary to accelerate the expansion of charging infrastructure throughout Germany, especially by removing obstacles in permitting procedures and in grid connection processes.
• The AFIR (Alternative Fuels Infrastructure Regulation) sets EU-wide targets based on distance and capacity through 2030. It should serve as the regulatory benchmark. Overregulation with unnecessary technical requirements should be avoided. In the revision of the regulation scheduled for the end of the year, the existing targets should be maintained and further interventions, especially in pricing, should be avoided.
• Dedicating public plots for the construction of new charging infrastructure at the federal, state, and municipal levels would also accelerate expansion. To this end, the expansion-relevant measures in the Charging Infrastructure Master Plan 2030 should be implemented promptly.
• It is important to ensure fair competition and market access for all market participants. This particularly concerns customers’ data sovereignty over vehicle and charging data. These data must not be restricted by individual market participants.
• The GHG quota (THG-Quote) represents an important pillar for refinancing charging infrastructure. The planned stabilization of this instrument as part of the amendment to the Second Act on the Further Development of the Greenhouse Gas Reduction Quota is to be welcomed.

In the current European legislative period, safeguarding and strengthening European competitiveness is at the center of the political agenda. The aim is to understand the transformation toward climate neutrality not only as a climate-policy obligation, but also as an economic opportunity, and to sustainably strengthen Europe’s industrial base in international competition.

With the Clean Industrial Deal presented in February 2025, the Commission established a strategic framework at an early stage to link decarbonization and competitiveness more closely. The focus is particularly on energy-intensive industries and key areas for net-zero technologies, which play a central role in achieving the goal of climate neutrality by 2050 while securing competitiveness against global competitors such as China and the United States.

To further specify this strategy, the Commission presented a proposal for an Industrial Accelerator Act (IAA) in early March 2026. The objective is to specifically strengthen demand for climate-friendly technologies and expand industrial value creation within the European Union. The focus is on stricter requirements for public procurement and for state support instruments.

Going forward, public tenders, auctions, and all forms of state intervention or support should be subject to binding minimum requirements regarding both Union origin and the level of decarbonization of key basic materials, including steel, aluminium, cement and mortar.

From EnBW’s perspective, the overarching objective of the legislative proposal - to diversify European supply more strongly and reduce dependence on market-dominant suppliers - is fundamentally welcome. Especially against the backdrop of international distortions of competition and one-sided trade practices, greater resilience in European supply chains can make an important contribution to securing industrial competitiveness.

At the same time, EnBW views critically the proposal’s planned minimum requirements in public procurement. As a public entity, EnBW will also be affected by these provisions. Especially in the German market environment, where public and private companies are in direct competition, there is a risk of structural competitive disadvantages and an uneven level playing field.

In addition, global procurement markets for renewable energy and net-zero technologies - for example in storage systems, electrolyzers, and grid infrastructure - are already extremely strained. The availability of key components is limited and delivery times are substantial in many cases. Against this background, additional regulatory requirements regarding origin and degree of decarbonization can be expected to further intensify price pressure in public procurement, especially in view of the massively increasing demand for technologies and infrastructure needed for the energy transition ramp-up.

While private market participants will continue to make their procurement decisions deliberately, EnBW, as a company with public-sector participation, would be subject to stricter regulatory requirements. This could result in significantly higher procurement costs and additional delays compared with private competitors. As a consequence investment projects might become uneconomical or would not be implemented at the required pace - with potentially negative effects on the expansion of renewable energy and the necessary development of grids and infrastructure.

Furthermore, increased costs along the value chain will eventually be passed on to end consumers, for example in the form of rising grid fees. This would place an additional burden on public acceptance of the energy transition.

Against this background, EnBW advocates that regulatory requirements be designed to ensure that all companies compete on equal terms. Legal requirements should not create systematic disadvantages for individual market participants but must guarantee a genuinely level playing field while enabling the rapid deployment of climate-neutral technologies.

EnBW supports the German federal government’s climate targets. They confirm our own transformation course with the goal of net-zero emissions and provide us with greater planning certainty.

The energy sector has so far significantly overachieved its targets for CO₂ reductions as defined in the Climate Protection Act. However, the other sectors must also contribute to reducing emissions. In particular, the pace of progress in the transport sector must increase significantly. The energy sector’s targets can only be achieved under the following conditions:

• The expansion of renewable energy must be accelerated significantly. The federal government has made considerable progress here, but this progress must be further stabilized.
• Work must now proceed quickly to create a mass-market for international hydrogen.
• Infrastructure expansion must be accelerated.
• In the buildings and transport sectors, emissions must decline rapidly and steadily through consistent electrification.

Effective CO₂ pricing as a market-based steering instrument should be pursued in all sectors. It provides the right incentives to achieve climate targets efficiently. The European Emissions Trading System (EU ETS) is the central pillar of CO₂ pricing in Europe. Companies covered by the EU ETS - sectors such as oil refineries, steel and aluminum production, power generation, aviation, etc. - must cover their emissions of climate-damaging gases (CO₂, nitrous dioxide, and perfluorocarbons) with emission allowances. These allowances must be acquired through auctions or through trading among companies. Total emissions under the EU ETS are politically defined, and the number of available allowances is reduced in line with climate targets.

The revision and expansion of the EU ETS implemented under the “Fit for 55” package also introduced several provisions that are in line with EnBW demands. For example, the overall level of ambition for emission reductions within the EU ETS was increased from the former -43% to -62% by 2030 (base year 2005).

In addition, EnBW welcomed the introduction of a separate emissions trading system for the buildings and transport sectors, the so-called “EU ETS II.” Despite the postponed introduction, ETS II is a central instrument for decarbonizing these sectors and achieving climate targets.

In Germany, a realignment of the tax, levy, and surcharge system based on the CO₂ intensity of the various energy carriers is urgently required. Despite the abolition of the EEG surcharge, the continued high burden of taxes, levies, and surcharges on the end-customer electricity price continues to hinder sector coupling and climate-friendly investments. In the short term, EnBW supports the reduction of the electricity tax to the European minimum rate and a reduction of the value-added tax.

EnBW also supports the gradual increase of the price path under the Fuel Emissions Trading Act (BEHG) and a continued important role for CO₂ pricing.

We consider the EU Taxonomy’s objective of creating a classification system for sustainable economic activities through clear standards and instruments to be an important tool for creating greater transparency regarding sustainable business activities, particularly for investors in the financial markets. EnBW welcomes the definition of sustainability set out in the Taxonomy Regulation. EnBW also welcomes the European Commission’s intention to review EU sustainability legislation overall with a view to reducing unnecessary reporting obligations. It is important to find a careful balance between effort and benefit:

• From EnBW’s perspective, it is important to also include the necessary investments for the interim steps of the transformation, as provided for in the Taxonomy Regulation in the shape of the transition category. Natural gas in particular is an important energy carrier for some member states, including Germany, as an interim step toward cost-effective decarbonization until sufficient green or decarbonized gas is available.
• In addition, the revision of the technical screening criteria must ensure that activities are not retrospectively reclassified. Such retrospective changes would lead to significant planning uncertainty for long-term investments.

EU Regulation on Artificial Intelligence (AI Act):

The EU AI Act regulates the use of artificial intelligence in the EU. Special requirements apply to high-risk AI applications. Within EnBW, various operational use cases are in use, ranging from predictive maintenance in distribution grids and offshore wind installations, to forecasting renewable electricity feed-in and consumption, to optimizing wind farm layouts.

EnBW’s main demands are:

• A clear definition of AI is needed that does not also cover conventional software.
• The “high-risk AI systems” category should be limited to systems that are unquestionably associated with high risk and have not yet been covered by applicable European and national product safety law.
• Compliance with legislative requirements should involve as little administrative burden as possible for companies of all sizes.
• Assessments of AI applications should, wherever possible, be carried out through a “self-assessment” procedure rather than through cumbersome third-party assessment.

Overall, the implementation of AI regulation must be as minimally restrictive as possible and must have a much stronger innovation-promoting effect. Complexity-reducing measures under the relevant EU omnibus packages are therefore to be welcomed. This is particularly true against the backdrop of global technological competition in the field of AI.

EU Data Act:

The legislation aims to create an EU internal market for data by enabling data sharing on a much larger scale, thereby generating value creation across sectors and across member-state borders.

In this context, new rights to data, especially product and industrial data, were also defined. From EnBW’s perspective, the basic principles of data access rights entail both opportunities and potentially greater effort. It is important that this new legislation fits with sector-specific regulation and that data security remains guaranteed in the operation of critical infrastructure.

EnBW operates numerous critical infrastructures across different sectors, including energy, telecommunications, transport, and water, and attaches very high importance to protecting these critical assets. Increasing the resilience of critical infrastructures (cybersecurity and physical protection) is indispensable due to the growing number and increasing complexity of threats.

The implementation of the European NIS2 Directive (cybersecurity) and CER Directive (physical protection) through the NIS2 Implementation Act and the KRITIS Umbrella Act is therefore a positive development. It is important that any increase in resilience requirements remains economically feasible. For the overall system to function, an exchange between critical infrastructure operators and the relevant authorities (BSI, BNetzA, BBK) is essential. Reporting obligations and reporting channels for critical events should be designed to be as streamlined, efficient, secure, and non-redundant as possible. Inconsistent double regulations must be avoided.

Effective support for critical infrastructure operators is only possible if the responsible authorities have sufficient expertise and capacity. Entrusted government agencies must ensure that sensitive information is not made accessible to unauthorized parties. For effective protection against drones, it is crucial that the responsibilities of public security authorities and the German armed forces are clearly defined and delineated. With regard to drone defense, EnBW opposes transferring the authority to shoot down drones to operators of critical infrastructure or private security services.

The German federal government has announced a revision of heat legislation and, in this context, presented the Building Modernization Act (GModG). While the abolition of the 65% rule creates a stable short-term framework for the natural gas market, it must be ensured that the transformation of gas grids toward hydrogen continues to move forward, that incentives for district heating are not weakened, and that climate targets in the buildings sector are not missed. The design of the announced bioenergy step model and green gas quota will also be decisive for the path to climate neutrality.

As part of the GModG, the Heat Planning Act (WPG) is also being revised. The key issue here is the right coordination between GModG and WPG in order to streamline building-energy requirements and reduce requirements for municipal heat planning. The WPG has so far established the foundations for introducing comprehensive heat planning across Germany. The federal states are required to ensure that heat plans are prepared within their territory by June 30, 2026 for major cities with more than 100,000 residents and by June 30, 2028 for municipalities with fewer than 100,000 residents. The obligation to carry out heat planning is already part of state legislation in some federal states, including Baden-Wuerttemberg, under the Climate Change Adaptation Act (KSG BW). In Baden-Wuerttemberg, “mandatory” heat planning for the 104 large and urban districts has already been completed. The amended Baden-Wuerttemberg Climate Protection and Climate Change Adaptation Act (KSG BW), which implements the requirements of the Heat Planning Act at the federal level, entered into force on August 6, 2025. A completely new Section 6, “Heat Planning,” was added. The heat planning obligation now applies to all municipalities in Baden-Wuerttemberg, regardless of their number of residents. Among other things, there is also a “simplified procedure” for smaller municipalities to prepare heat planning. Financing is regulated through so-called connectivity payments from the state to the municipalities.

From our perspective, the Heat Planning Act pursues a fundamentally sensible objective, but there are challenges in practice. The following points should therefore be considered in the context of municipal heat planning:

• Measures resulting from municipal heat planning are currently, for the most part, not economically feasible. A heat plan that makes sense from a macroeconomic perspective does not automatically constitute a sound business case from a business-management perspective.
• From our perspective, those responsible for implementing heat planning must therefore have clarity on how the measures resulting from municipal heat planning will be financed.
• To facilitate the financing of investments, two central aspects must be addressed:
• A larger number of investor groups and more capital must be mobilized for the heat transition.
• From a macroeconomic perspective, the technologies that cause the lowest macroeconomic costs should be used.
• Nevertheless, individual investment decisions must be made by private individuals, companies, and municipal bodies. Here, the business-management perspective is central, including the question of whether an investment pays off over its lifetime.
• To accelerate implementation of the heat transition, a reliable legal and economic framework for the next 10 to 15 years is an obvious necessity - for companies such as EnBW, municipal utilities, and private capital investors alike.

Storage systems are an integral component of a wide range of EnBW business models. Through SENEC, EnBW has been active in the home storage market for several years and offers customers complete solutions for their homes (a combination of PV system, heat pump, home EV-charger, battery storage system, and home energy management system (HEMS)). EnBW is the market leader in the expansion of charging infrastructure. Initial pilots are underway here to use storage systems and address the increasing challenges associated with grid connections for charging parks.

Pumped storage: EnBW operates two of its own plants, Glems and Forbach, and also holds direct and indirect interests of around 50% in Schluchseewerk AG (the Schluchsee cascade with three pump-storage plants, as well as the Saeckingen and Wehr pumped-storage plants). The Forbach pumped-storage plant is currently under construction (modernization and capacity expansion); expansion and modernization of the Schluchsee cascade is in preparation. For the first stage, Haeusern, the planning approval procedure is underway at the Freiburg Regional Council. With their performance capacity and speed, pumped-storage plants are a life insurance policy for the transmission grids, including black-start capability.

Large-scale battery storage: Since 2023, all ground-mounted photovoltaic systems have been combined with battery storage systems. This increases their flexibility and enables production to be more closely aligned with demand. Existing solar parks are being retrofitted. Stand-alone large-scale storage systems are being developed at the former and current power plant sites of Marbach (100 MW/100 MWh) and Philippsburg (400 MW/800 MWh), benefiting from the site advantage of an existing grid connection. Benefit: flexibility, speed, and system services for security of supply and system stability.

Storage systems have therefore become indispensable in today’s energy world. However, there are several opportunities for optimization on the regulatory side.

One example in the home storage segment would be the legal simplification of multi-use operation for home storage systems. With the further expansion of renewable energy, the provision of flexibility and secured capacity in the electricity system is becoming increasingly important. Electricity storage systems can make an important contribution here if the regulatory framework is right. This applies in particular in the context of current and increasingly stringent future requirements for prosumers, such as the suspension of remuneration during negative electricity prices and the planned lowering of the threshold for a mandatory direct marketing obligation. In these cases, multi-use deployment of electricity storage systems can provide additional economic options for system operators. However, current requirements lead, among other things, to considerable barriers and effort in multi-use operation and to double burdens from levies and surcharges. To enable storage systems to be used comprehensively for various flexibility products - self-consumption optimization, grid-serving charging, provision of balancing energy, etc. - the legal framework must be consistently revised:

• Storage systems must be fundamentally recognized as part of the solution and defined as an independent pillar of the energy system.
• A legal definition of electricity storage should clarify that electricity storage systems are generally not final consumers.
• The Federal Network Agency is currently discussing the early termination of the legally guaranteed exemption of storage systems from grid fees under Section 118(6) of the Energy Industry Act in the so-called AgNes process. However, exemption of electricity storage systems from grid fees and other final-consumer charges is a central prerequisite for the economic viability of storage systems. Legitimate expectations for currently planned investments in storage systems must be protected in order to prevent damage to Germany as a business location.
• A pragmatic and timely approach to multi-use storage systems is needed, for example without burdensome technical and process-related requirements.

Storage systems are also playing an increasingly important role in electromobility. The implementation in national law of the right, regulated under European law, to non-discriminatory and free access to data from car batteries and home storage systems is therefore indispensable.

In order to offer corresponding flexibility products in the market, such as bidirectional charging, all flexibility providers must receive corresponding access to storage data from manufacturers, such as state of health and state of charge. This right is already anchored in the EU Renewable Energy Directive (RED III), but has not yet been transposed into national law. Implementation as quickly as possible is necessary so that:

• Households have the option, through third parties, to display the charging levels of their storage systems or electric vehicles, for example - barrier-free and in the app of their choice.
• Manufacturers’ proprietary systems do not otherwise prevent competition and make access to so-called energy-transition technologies cumbersome and complicated.

Supplement on Large-Scale Storage

• Permitting procedures for pumped-storage plants currently take up to 15 years. They must be drastically accelerated and simplified.
• For large-scale battery storage systems, a pragmatic legal solution is needed for grid connection that rewards multiple use of grid connection points and takes the seriousness of planning into account.