New developments on grid fee reform: BNetzA orientation points of January 16, 2026

What the German Federal Network Agency's orientation points of January 16, 2026 mean in practice

Multi-use storage systems, used both for self-consumption optimization and for arbitrage, balancing energy or grid-supportive operation, are regarded as a key flexibility option for the energy transition. At the same time, they sit in a regulatory field of tension between grid financing, market integration and consumer protection.

With its orientation points on storage grid fees of January 16, 2026, the German Federal Network Agency (BNetzA) has, for the first time, set out how this field of tension is to be resolved going forward. Even though many questions of detail remain open, the paper points to clear guidelines that are already relevant today for installers, project developers, storage manufacturers, wholesalers, municipal utilities and EMS providers.

1. Introduction and status quo: new rules, open implementation

The starting point for the current discussion is the amendment of Section 118 (6) of the German Energy Industry Act (EnWG) in December 2025. This amendment extends the grid fee exemption for electricity storage to so-called mixed-flow or multi-use storage systems. It now also covers storage systems in which only part of the stored energy is fed back into the grid, while another part is consumed behind the connection point.

The aim of this legislative change is clear:

Arbitrage and market-oriented storage operation should not be devalued by grid fees.

At the same time, the practical implementation has so far remained unresolved. In particular, there is no binding answer to the question of how, in practice, to distinguish between storage-related market movements and consumption-related use. This is exactly where the planned MiSpeL (the BNetzA's metering and storage logic) comes in (more on this here). In the future, it is intended to define how stored electricity is delineated for metering and balancing purposes.

In parallel, with AgNes (the general grid fee framework for electricity), the fundamental reform of grid fees following the expiry of the StromNEV is underway. The orientation points are part of this AgNes process and mark the current state of regulatory considerations — still without binding determinations, but with a clear direction.

2. Key statements of the orientation points of January 16, 2026

In its paper, the Federal Network Agency makes several fundamental decisions clear:

• A permanent full exemption from grid fees for storage systems is untenable under European law and energy industry principles.

• In the future, storage systems should generally contribute to financing the grids.

• At the same time, storage systems should not be penalized for grid-supportive behavior, but specifically rewarded for it.

• Multi-use storage systems take on a special role, as they fulfill both consumption-like and market-oriented functions.

To reconcile these objectives, the BNetzA distinguishes for the first time systematically between grid fees with a financing function and grid fees with an incentive function.

3. Grid fees with a financing function: paying for actual grid use

Grid fees with a financing function serve exclusively to cover grid costs. In the future, they are intended to consist of two elements.

Capacity component:

Instead of the technical connection capacity, a reserved capacity chosen by the grid user is decisive. It determines a fixed cost share and is intended to finance the long-term provision of grid capacity.

Energy prices (AP1 / AP2):

As long as power drawn stays within the reserved capacity, a lower energy price (AP1) applies. If the capacity is exceeded, a higher energy price (AP2) takes effect, creating incentives for realistic capacity choices.

4. Grid fees with an incentive function: rewarding flexibility in a targeted way

To complement the financing function, the BNetzA plans to introduce dynamic grid fees with an incentive function. These do not serve financing purposes, but rather the targeted steering of grid usage behavior.

They are characterized by:

• a time- and location-dependent design,

• a symmetric application to supply and feed-in,

• and a sign-correct effect.

Grid-relieving behavior — such as charging during grid congestion or feeding in during bottlenecks — can lead to credits. Grid-burdening behavior can cause additional costs. For the first time, this gives storage systems the opportunity to generate direct revenues through the grid fee regime by operating in a grid-supportive way. The ruling chamber is aiming to introduce grid fees with an incentive function from 2029 for the transmission grid and the high-voltage level.

5. Interplay with Section 118 (6) EnWG and MiSpeL for multi-use storage systems

For multi-use storage systems, the interplay of the different rule sets is decisive. The statutory exemption under Section 118 (6) EnWG protects storage-related market movements, in particular arbitrage. However, it does not protect final consumption.

In concrete terms, this means:

• Electricity flows grid → storage → grid should be exempt from grid fees with a financing function.

• Electricity flows grid → storage → consumer count as normal consumption and remain subject to fees.

For this delineation to work in practice, MiSpeL is central (more information in the article here). Only if it is clearly defined and measured which electricity volumes are stored, fed back in or consumed can Section 118 (6), netting and the new grid fees be implemented consistently.

6. Two calculation examples — explained concisely

To illustrate this, we consider a multi-use storage system at a commercial connection point that can charge electricity from the grid, feed electricity into the grid and use electricity on site.

Basic assumptions (the same for both examples)

For the grid fees with a financing function, the following assumptions apply:

• Reserved capacity: 1 MW

• Energy price within the reserved capacity (AP1): 20 €/MWh

• Capacity price: 10 €/MW per hour

• Observation period: 4 hours

The capacity price is therefore:

1 MW × 10 € × 4 h = 40 €

For the grid fees with an incentive function, the following (simplified) dynamic prices are assumed:

• Power drawn during a surplus hour: −80 €/MWh

• Power drawn during a congestion hour: +100 €/MWh

• Electricity feed-in during a congestion hour: −50 €/MWh

Schedule of the storage system and the site

The storage system and the site behave the same in both examples:

• At night, the storage system charges 1.0 MWh from the grid.

• In the morning, the storage system discharges 1.0 MWh:

  • 0.6 MWh are fed into the grid,

  • 0.4 MWh are consumed on site.

• In addition, the site draws 1.5 MWh directly from the grid at midday.

• The storage losses amount to 0.1 MWh.

The only difference between the two examples is the grid situation during the midday power draw.

Example 1: The midday power draw is grid-neutral

In this case, the additional grid supply of 1.5 MWh falls in an hour without grid congestion.

Financing function

For the financing function, only those electricity volumes are considered that are not fed back into the grid:

• Self-consumption from the storage system: 0.4 MWh

• Storage losses: 0.1 MWh→ volume subject to fees: 0.5 MWh

Calculation:

• Storage energy price: 0.5 MWh × 20 €/MWh = 10 €

• Capacity price: 40 €

• Site energy price: 1.5 MWh × 20 €/MWh = 30 €

Financing function total: 80 €

Incentive function

• Charging during surplus hour: 1.0 MWh × (−80 €/MWh) = −80 €

• Feed-in during congestion hour: 0.6 MWh × (−50 €/MWh) = −30 €

Incentive function total: −110 €

Overall result for Example 1

80 € − 110 € = −30 €

In this case, the site generates a net revenue of 30 €.

Example 2: The midday power draw falls in a congestion hour

In this second case, only one thing changes:

The additional grid supply of 1.5 MWh now takes place during a congestion hour.

Financing function

Unchanged from Example 1:

• 80 €

Incentive function

• Charging during surplus hour: −80 €

• Feed-in during congestion hour: −30 €

• Power drawn during congestion hour: 1.5 MWh × +100 €/MWh = +150 €

Incentive function total: +40 €

Overall result for Example 2

80 € + 40 € = 120 €

In this case, the site pays 120 € in additional grid fees.

Brief comparison of the two examples

With an identical storage system, an identical schedule and identical consumption, the results differ solely due to the grid situation at the time of the power draw:

• Example 1: −30 €

• Example 2: +120 €

The difference arises solely from the dynamic grid fees with an incentive function, not from the storage size or the installed technology.

7. Open questions and challenges

Despite clear guardrails, key questions remain open. Project developers and manufacturers need to clarify how bankable business models with dynamic and potentially volatile grid fees are. Municipal utilities and grid operators face the task of integrating new incentive fees with existing instruments such as individual grid fees under Section 19 StromNEV. EMS providers have to bring market and grid signals together both technically and economically.

Added to this are questions of IT implementation, data transparency, abuse prevention and non-discrimination under European law. The greatest challenge lies less in the technology than in the coherent integration of the rule sets.

Conclusion

The Federal Network Agency's orientation points mark a fundamental paradigm shift. In the future, storage systems will no longer be privileged across the board, but treated in a differentiated way. At the same time, flexibility is being systematically integrated into the grid fee framework for the first time and potentially remunerated. This creates new opportunities for multi-use storage systems — provided that metering concepts, operating strategies and business models are adapted to the new logic at an early stage.