Implementation Plan for Publicly Communicated Climate and Environmental Targets

The reduction targets of 83% by 2035 and at least 95% by 2040 apply to the sum of direct emissions from assets owned or controlled by the company (Scope 1) and indirect market-based emissions from purchased energy (Scope 2), compared with the 2018 base year.

• Coal phase-out: EnBW aims to phase out coal-fired power generation by 2028, provided that the necessary framework conditions are in place and security of supply is not jeopardized. Installed coal-fired generation capacity has already been reduced significantly compared with 2018. In 2026, only three plants with a combined capacity of approximately 1.4 GW remain in operation.
• Construction of fuel-switch power plants: To support the coal phase-out, EnBW is replacing coal-fired power plants at selected sites with hydrogen-ready combined-cycle gas turbine plants. The Stuttgart-Münster power plant entered service in 2025. The Altbach/Deizisau and Heilbronn sites are under construction and, based on current planning, are scheduled to enter service in 2027. Switching from coal to natural gas is expected to reduce greenhouse gas emissions at the affected sites by approximately 60% while maintaining security of supply.
• Fuel switch to hydrogen and other gases with lower lifecycle emissions: Current plans call for the hydrogen-ready power plants to be fully converted to hydrogen at a later stage. Both blue hydrogen, produced from natural gas with capture and storage of the resulting CO₂, and green hydrogen, produced through electrolysis using electricity generated from 100% renewable energies, may be used. Other decarbonization options are being assessed in parallel, particularly for plants not designed to be directly hydrogen-ready. These options include biomethane. Decisions on the use of gases will be based on verified lifecycle emissions, including upstream emissions, the availability of suitable supply volumes, and applicable regulatory and sustainability requirements.
• Decarbonization of heat supply and reduced operation of gas networks: Heat-related emissions will be reduced primarily through the coal phase-out, the use of efficient combined heat and power plants and their subsequent conversion to gases with lower lifecycle emissions, and the integration of new technologies such as large-scale heat pumps or, where feasible, geothermal energy. These technologies are already in use, for example, at the Stuttgart-Münster site and in Bruchsal.
  By decarbonizing its own heat generation, EnBW is contributing to Germany's heating transition. Together with the transformation of the power plant portfolio and the decarbonization of industrial processes, for example through electrification or the replacement of fossil fuels with fuels that have lower lifecycle emissions, demand for natural gas in Germany is expected to decline over time. As a result, emissions from operating gas networks in the EnBW Group will decrease in the long term.
• Reduction of emissions from reserve and redispatch operations: As the power plant portfolio is transformed and power grids are expanded, emissions from reserve operations, meaning the system-stabilizing use of plants that have already been shut down at the request of the transmission system operator, and redispatch measures, meaning system-stabilizing measures involving operating plants at the request of the transmission system operator, are expected to decline over the long term. Additional contributions will result from transmission grid expansion, reduced grid congestion, and the replacement of fossil reserve capacity with lower-emission alternatives.
• Use of renewable electricity for suitable generation-related consumption: EnBW continuously assesses the extent to which renewable electricity can be used for suitable generation-related consumption in an economically and regulatorily viable manner. This measure can make an additional contribution to reducing market-based Scope 2 emissions.
• Contribution to the decarbonization of Germany's electricity mix through renewable energies expansion: EnBW aims to expand installed renewable energies capacity to between 10.0 and 11.5 GW by 2030. The 2025 expansion target has already been achieved. In 2025, installed capacity totaled approximately 7.4 GW, and the share of renewable energies in the generation portfolio was significantly above the level originally targeted. In addition, an extensive project pipeline is under development or construction. Further renewable energies expansion contributes both directly to reducing EnBW's own emissions and indirectly to decarbonizing the German electricity system.
• Procurement of electricity generated from 100% renewable energy sources for grid losses: Based on the current interpretation of the law, electricity generated from 100% renewable energy sources cannot be procured for the energy losses that are unavoidable in grid operations. Netze BW and naturenergie already use an approach intended to achieve a comparable energy market effect by permanently withdrawing from the market a corresponding volume of Guarantees of Origin for electricity generated from 100% renewable energy sources. This significantly reduces the Scope 2 emissions associated with grid losses. Continuation of this approach is an important contribution to reducing market-based Scope 2 emissions.

The EnBW generation business unit and the subsidiaries and equity investments Valeco, ZEAG, and Stadtwerke Düsseldorf (SWD) are primarily responsible for planning and implementing the key measures for the generation portfolio and for providing progress data. The electricity and gas grid companies relevant to the implementation of these measures include Netze BW, TransnetBW, ONTRAS, terranets bw, naturenergie, Pražská energetika (PRE), and SWD. The sustainability department coordinates Group-wide target setting and progress reporting.

EnBW plans total investments of up to €50 billion through 2030. Of this amount, 25% to 30% is allocated to the segment “Sustainable Generation Infrastructure”. Approximately €5.1 billion is planned for 2026 through 2028, including €2.5 billion for renewable energies expansion. €2.2 billion is planned for the thermal generation portfolio, with the majority allocated to completing the fuel-switch projects in Heilbronn and Altbach/Deizisau. The Stuttgart-Münster fuel-switch power plant has already entered service.

EnBW's grid subsidiaries will continue to expand transmission and distribution networks for electricity and gas and, in the longer term, hydrogen. Between 60% and 70% of the investments of up to €50 billion through 2030 are planned for the segment “System Critical Infrastructure”. Approximately €1 billion is planned for EnBW's contributions to the hydrogen core network. For the period from 2026 to 2028, investments of €16 billion are planned for this segment, primarily comprising grid infrastructure.

Of the total investments of €22.3 billion planned for 2026 through 2028, more than 85% are expected to meet the EU Taxonomy alignment criteria. In addition to the two segments described above, this total includes €1.2 billion in the segment “Smart Infrastructure for Customers”, primarily for charging infrastructure; these investments do not contribute to the stated reduction targets. EU Taxonomy alignment means that the investments are made exclusively in economic activities that, under EU criteria, make a substantial contribution to climate change mitigation while also complying with specified additional environmental and social safeguards.

The following assumptions and dependencies are monitored regularly and reviewed for continuing validity as part of the annual update to the scenario framework. Changes in the underlying premises are incorporated into the implementation plan and the planned measures as needed.

• Security of supply must be maintained
• Regulatory approvals for power plant shutdowns
• Required infrastructure, particularly the electricity transmission grid and the hydrogen core network
• Suitable energy carriers in sufficient quantities and at economically viable prices
• Developments in the emissions intensity of the electricity mix, fuel prices, demand, power plant dispatch, and reserve and redispatch requirements

Note: In individual years, emissions in specific areas of the company's footprint may increase compared with the prior year or the base year, for example as a result of additions to or conversions within the generation portfolio. Such temporary or one-time effects do not, in themselves, permit conclusions regarding achievement of the communicated targets.

After the physical greenhouse gas emission reductions for Scopes 1 and 2 have been achieved, the remaining emissions shall be additionally compensated through climate action projects beginning in 2035. Residual emissions of approximately 2.2 million metric tons of CO₂e are currently expected for 2035. The principle of “reduction before compensation” applies: compensation serves exclusively to address remaining residual emissions, does not replace any emission reduction measure, and is not counted toward the physical emission reduction target.

For the 2040 net-zero target, remaining residual emissions will be neutralized through greenhouse gas removals, either within EnBW’s own value chain or through certificates from suitable external projects. The specific approach will be reviewed regularly and further developed in light of technological developments, regulatory requirements, scientific findings, and available solutions.

To date, emissions compensation has played only a minor role within EnBW because the focus is on physical emission reductions. Development of a larger project portfolio and procurement of the relevant certificates have not yet begun because the stipulated maximum certificate age means that certificates can only be purchased close to the time they are intended to be used.

Binding quality criteria will be defined for the supplementary compensation of remaining emissions. These criteria include, in particular, independent verification, additionality, permanence, avoidance of double counting, transparent registry management, requirements regarding certificate age or vintage, project type and location, and, where applicable, corresponding adjustments. The instruments used are intended to meet EnBW’s applicable quality requirements and will be documented transparently.

The sustainability department monitors the development of suitable compensation and neutralization solutions and continues to develop the applicable quality requirements across the Group. Decisions on the use of specific instruments and the provision of financial resources are made through the applicable planning, budgeting, and approval processes.

Required resources depend directly on the actual volume of residual emissions and on the neutralization solutions available and recognized at the relevant time. Detailed resource planning will therefore be conducted as part of the regular update to the implementation plan, based on the then-current residual emissions forecasts.

The following assumptions and dependencies are monitored regularly and reviewed for continuing validity as part of the annual update to the scenario framework. Changes in the underlying premises are incorporated into the implementation plan and the planned measures as needed.

• Volume and composition of remaining Scope 1 and Scope 2 residual emissions after implementation of the reduction measures
• Availability of suitable technological and nature-based neutralization solutions at sufficient scale
• Further development of quality standards, regulatory requirements, and market mechanisms for certificates and greenhouse gas removals
• Availability of high-quality compensation and neutralization certificates at economically viable terms

• Transformation of the gas sales and distribution portfolio: EnBW is gradually aligning its sales, procurement, and trading portfolios toward lower sales volumes of emissions-intensive energy carriers. Changes already implemented relate in particular to parts of the B2B gas business and the continued development of products and customer solutions with lower greenhouse gas emissions.
• Replacement of natural gas with gases that have lower lifecycle emissions: For suitable applications, the target pathway provides for the gradual replacement of natural gas with biomethane, hydrogen, and hydrogen derivatives such as ammonia that have lower lifecycle emissions. This includes biomethane as well as blue hydrogen, produced from natural gas with capture and storage of the resulting CO₂, and green hydrogen, produced through electrolysis using electricity generated from 100% energy from renewable sources. Decisions on the use of gases will be based on verified lifecycle emissions, including upstream emissions, the availability of suitable supply volumes, and applicable regulatory and sustainability requirements.
• Discontinuation of coal sales to end customers: In connection with the coal phase-out, EnBW is discontinuing sales of small quantities of coal to end customers. The associated Scope 3 emissions from the use of sold coal will therefore be phased out.

Depending on the respective emissions source, operational responsibility lies with the relevant units for sales, trading, grid infrastructure, and the relevant equity investments along the gas value chain. The sustainability department coordinates Group-wide target setting, emissions reporting, and progress reporting.

Reducing Scope 3 emissions requires, in particular, adjustments to sales, procurement, and trading portfolios and the continued development of products and customer solutions. The resources required relate less to additional capital investment than to the strategic transformation of the business portfolio, the allocation of personnel, and acceptance of potential effects on sales volumes and margins for emissions-intensive products.

The following assumptions and dependencies are monitored regularly and reviewed for continuing validity as part of the annual update to the scenario framework. Changes in the underlying premises are incorporated into the implementation plan and the planned measures as needed.

• Declining natural gas demand resulting from external decarbonization measures and technology changes, such as increased use of heat pumps
• Expansion of district heating, gas, and hydrogen infrastructure
• Availability and economic viability of biomethane and hydrogen with lifecycle emissions low enough to satisfy regulatory requirements
• Development of customer preferences, the regulatory framework, and the market

Note: In individual years, emissions in specific areas of the company's footprint may increase compared with the prior year or the base year, for example in years with unusually cold weather that increases gas demand. Such temporary or one-time effects do not, in themselves, permit conclusions regarding achievement of the communicated targets.

The operational environmental targets are achieved primarily through changes in the generation portfolio, particularly the coal phase-out, and through plant-specific measures.

The targets will be achieved primarily through the coal phase-out, provided that the necessary framework conditions are in place and security of supply is not jeopardized, changes in the fuel mix, expansion of renewable energies, and plant-specific environmental measures.

To maintain a waste recovery rate of at least 95%, the existing measures are to be continued: separate collection, reuse and material recovery, requirements for waste disposal contractors, and site-level waste management.