How will the KraftNAV reform affect PV investors and businesses?
KraftNAV determines who gets connected to the grid and when. Since the amendment in December 2025, it has been one of the most important factors for ground-mounted PV projects and battery storage systems—even for systems that do not fall within its scope.
The short answer
KraftNAV applies to grid connections of 110 kV and 100 MW or higher. The amendment of December 24, 2025, excludes battery storage systems from being treated as conventional power plants and paves the way for a shift from the first-come, first-served principle to a maturity-based assessment process. It does not apply directly to smaller PV systems—its impact is felt through the waiting list at the substation, which most recently included approximately 720 GW in connection requests.
For years, the Power Plant Grid Connection Ordinance (KraftNAV) was considered a side issue. Since the amendment in December 2025, the KraftNAV has become one of the most important levers for PV investors and battery storage projects: It determines who gets connected to the grid and when. This article explains what has changed, which facilities are affected, and which deadlines apply in 2026 and 2027.
What does the KraftNAV regulate—and who does it apply to?
KraftNAV regulates the grid connection of large-scale generation facilities to the extra-high- and high-voltage grids. It applies to facilities with a connection voltage of 110 kilovolts or higher and a rated capacity of 100 megawatts or more. It therefore does not directly apply to rooftop and ground-mounted PV systems in the single-digit megawatt range.
The indirect effect is important. KraftNAV determines how grid operators allocate scarce connection capacity. Anyone who wants to feed power into the grid in the same grid region competes with these large-scale projects for the same substations—even if their own facility never falls within the scope of the regulation.
Battery storage systems have long been a special case in this context. They are neither traditional generators nor pure consumers, and the regulation was not tailored to them. This is precisely where the amendment comes in.
Why the "first-come, first-served" principle Became a Problem
Connection capacity was allocated on a first-come, first-served basis: whoever applies first gets served first. The German Association of Energy and Water Industries estimated the number of pending connection requests in November 2025 at around 720 gigawatts—compared to an installed generation capacity of approximately 263 gigawatts in Germany.
A significant portion of these inquiries was for projects that would never be built. Reserved capacity thus blocked actual projects. The result was paradoxical: projects that were ready for construction—with financing, land, and permits in place—were taking a back seat to inquiries that would never result in a facility.
The Federal Court of Justice addressed this practice in its decision of July 15, 2025 (EnVR 1/24) and granted grid operators greater discretion in the allocation process. This paved the way for a reform of the regulation.
What the December 2025 amendment entails
The amending regulation was promulgated on December 24, 2025 (Federal Law Gazette 2025 I No. 368). The key change is a revised sentence in § 1(1) of the KraftNAV: Battery storage systems are no longer automatically treated the same as conventional power plants. The previous cost privilege for storage systems has been eliminated.
In practice, this means three things. First, connection costs for storage facilities will no longer be allocated on a flat-rate basis, as is the case with generation facilities. Second, grid operators will be able to integrate storage facilities more flexibly into existing connection points. Third, this paves the way for an allocation process that is no longer based solely on the timing of the request.
For open-space projects that include planned storage facilities, this is the most significant change of the past two years. It determines whether a storage facility can be built at the same connection point or requires a separate permitting process.
Which PV systems are affected—and which are not
Roof-mounted systems in the low- and medium-voltage grids, as well as ground-mounted systems below the 110-kilovolt threshold, are not affected. Large-scale projects of 100 megawatts or more connected to the high-voltage grid are directly affected. The vast majority are indirectly affected—due to the waiting time at the substation.
For rooftop and smaller ground-mounted systems, grid connection continues to be governed by the EEG and the technical connection rules, not by the KraftNAV. In Germany, there are only a limited number of solar farms exceeding the 100-megawatt threshold; the regulation for wind and storage is more relevant in practice.
The practical benefit lies in the queue: When inactive projects are dropped from the list, active projects move up. Anyone planning an open-space project in a region with a strained grid situation benefits directly from this—even if they are not subject to the regulation themselves.
Co-location: Storage at solar parks is becoming easier
Co-location refers to a battery storage system located at the same grid connection point as the PV system. The German Solar Industry Association estimates that about 90 percent of new solar farms will be planned with storage. A shared connection point typically saves between 50,000 and 150,000 euros compared to two separate connections.
Revenue is also on the rise. A white paper analysis from February 2026 shows that co-located systems offer a net present value advantage of about 29 percent over the stand-alone option. The article on PV with battery storage and co-location breaks down the revenue streams in detail.
In addition, there is the grid fee exemption under Section 118(6) of the Energy Industry Act (EnWG). Storage facilities that become operational within 18 years of August 4, 2011, are exempt from grid fees on purchased electricity for 20 years. This timeframe thus ends in early August 2029. Whether the exemption will be extended beyond that date remains to be determined in the ongoing AgNes proceedings—see the article on the AgNes reform and 2026 grid fees for further details.
The Maturity Model: Alignment Based on Project Maturity
Since April 1, 2026, grid operators have been testing a maturity assessment process. Instead of a timestamp, the proven project status is the deciding factor: securing the site, obtaining permits, securing financing, and signing a supply contract for the main components. The process consists of three phases—preliminary inquiry, proof of maturity, and binding commitment.
Anyone who fails to submit the required documentation by the deadline will lose their place in the queue. The fee structure is also changing: The processing fee will increase to a base amount of 50,000 euros plus 1,500 euros per megawatt; previously, it was around 1,000 euros per megawatt. The higher fee is intentional—it makes frivolous inquiries more expensive.
Netze BW was one of the first distribution system operators to expand the procedure and now applies it to connection requests of 950 kilowatts or more, as well as to stand-alone storage systems. For project developers, this means that the burden of proof begins well below the KraftNAV threshold.
There has been criticism regarding the depth of the assessment. The Federal Network Agency is calling on network operators to adopt transparent and uniform criteria to ensure that the maturity assessment does not become a matter of discretion.
What this means for investors
For investors, the reform shifts the focus of the review: It is not the timing of the connection request that matters, but rather the project’s feasibility. Grid connection status, documentation of the project’s maturity, and a prepared storage option thus become factors affecting the purchase price.
There are three key points that should be included in every due diligence process. First, the grid connection status: Is there a binding commitment, or just a preliminary inquiry? Second, the maturity documentation—site acquisition, permits, and component contracts. Third, the storage option: A project with a prepared co-location connection should be valued differently on the secondary market than one without.
At the same time, the transition of the support scheme is underway. According to Article 19d of the Electricity Market Regulation, as amended by Regulation (EU) 2024/1747, direct price support for contracts concluded on or after July 17, 2027, must be structured as bilateral spread contracts. The German government’s draft bill for the EEG 2027 passed the Cabinet on July 29, 2026; the Bundestag and Bundesrat are still deliberating. Plants that go into operation by the end of 2026 will retain their grandfathering status. The article provides details on the CfD requirement effective in 2027.
What this means for businesses with their own facilities
The KraftNAV does not change the connection procedure for commercial facilities. Its impact is indirect: where grid capacity is scarce, commercial connections are also delayed. The key driver of returns remains the avoided grid procurement costs—the BDEW reports a rate of 16.7 cents per kilowatt-hour for new contracts with small and medium-sized industrial customers in April 2026.
According to the Federal Statistical Office, smaller commercial purchases of less than 20 megawatt-hours are significantly higher than that. Every kilowatt-hour consumed on-site replaces this purchase—that is the real lever, not the feed-in tariff.
Two rules of thumb have proven useful for sizing storage systems: approximately one kilowatt-hour of usable capacity per kilowatt-peak of system output for optimizing self-consumption, and, for peak load capping, sizing based on the power to be capped rather than on capacity.
For tax purposes, the window remains open until the end of 2027. The investment tax credit (up to 50 percent, § 7g(1) EStG), special depreciation (40 percent, § 7g(5) EStG), and declining-balance depreciation apply concurrently. Declining-balance depreciation amounts to no more than three times the straight-line depreciation, capped at 30 percent—for photovoltaic systems with 5 percent straight-line depreciation, this amounts to 15 percent; for battery storage systems, the 30 percent cap is reached. Cumulatively, up to 77.5 percent can be claimed over two years; in the year of investment alone, this amounts to 27.5 percent, because the investment deduction is already applied in the previous year. The article on photovoltaic depreciation calculates this in detail.
Don't forget: Registration in the Market Master Data Registry must be completed within one month of commencement of operations.
Key Figures at a Glance
The six values most commonly used in KraftNAV questions—including their status and source. All information is current as of August 2026.
| Key figure | Value | Source / Date |
|---|---|---|
| KraftNAV Application Threshold | 110 kV and 100 MW and above | § 1(1) KraftNAV |
| Pending Grid Connection Requests | about 720 GW | BDEW, November 2025 |
| Maturity Model Under Testing | since April 1, 2026 | Utility Company, 2026 |
| Processing Fee for Connection Application | 50,000 € + 1,500 €/MW | Maturity Model, 2026 |
| Exemption from Storage Grid Fees | Commissioning by early August 2029 | Section 118(6) of the Energy Industry Act (EnWG) |
| CfD Requirement for New Funding Agreements | Starting July 17, 2027 | Art. 19d of Regulation (EU) 2024/1747 |
Clarify the utility connection early on—we'll review your project
Whether it's an open-space project, a commercial storage facility, or a colocation facility: We'll review the grid connection status, maturity documentation, and storage options, and let you know where your project stands in the queue.
Frequently Asked Questions
Does KraftNAV apply to my rooftop solar system?
No. KraftNAV applies only to systems with a connection voltage of 110 kilovolts or higher and a capacity of 100 megawatts or higher. Roof-mounted systems connected to the low- and medium-voltage grids are not covered. You are affected only indirectly through the load on the regional grid.
What has changed as of December 2025?
The Amending Regulation of December 24, 2025, revised the scope of application in § 1(1) of the KraftNAV. Battery storage systems are no longer automatically treated like conventional power plants; the previous cost privilege no longer applies; and the way is now clear for a procurement process based on project maturity.
What is the maturity assessment process?
A procurement process in which what matters is not the timing of the request, but the documented status of the project. The process evaluates land acquisition, permits, financing, and component contracts. It has been in a pilot phase in Erprobung since April 1, 2026; Netze BW applies it to projects starting at 950 kilowatts.
How long must a storage system be in operation to be exempt from grid fees?
Under Section 118(6) of the Energy Industry Act (EnWG), storage facilities that are commissioned within 18 years of August 4, 2011, are exempt. This time frame ends in early August 2029. The exemption then applies for 20 years from the date of commissioning with respect to the procurement of the energy to be stored.
When does the CfD requirement take effect?
According to Article 19d of the Electricity Market Regulation, direct price support for contracts effective July 17, 2027, must take the form of bilateral spread contracts. The draft of Germany’s EEG 2027 passed the Cabinet on July 29, 2026, but has not yet been enacted.
Is it more worthwhile to install a storage system at a solar park right now?
In many cases, yes. The shared connection point typically saves between 50,000 and 150,000 euros, and according to an analysis from February 2026, co-located projects have a net present value that is approximately 29 percent higher. The specific local grid situation remains the decisive factor.
Conclusion
The KraftNAV amendment is not a minor adjustment, but rather a systemic change in how scarce grid capacity is allocated. It applies directly to large-scale projects and, for all others, through the waiting list. Anyone planning an open-space project or a commercial storage facility in 2026 should begin the grid connection process earlier and with more comprehensive documentation than before.
Every timeline must include two deadlines: the storage window under Section 118(6) of the Energy Industry Act (EnWG), which runs until early August 2029, and the CfD transition for contracts effective July 17, 2027. The articles on Section 14a of the EnWG and battery storage, as well as on ground-mounted photovoltaic systems, illustrate how a project’s financial viability is affected by these factors.
Important Note: This article is intended solely for general informational purposes and does not constitute investment, tax, or legal advice. Information regarding returns, income, proceeds, lease payments, and costs consists of sample calculations or market observations as of the date indicated and does not constitute a guarantee of future results; the actual values that can be achieved depend on location, system design, contract terms, and market developments. The legal situation described reflects the status as of the date specified. Where drafts are referenced, they do not constitute applicable law; changes may occur during the course of the proceedings. Regulatory proceedings regarding KraftNAV, the maturity assessment procedure, AgNes, and the EEG 2027 are ongoing; the status of these proceedings must be re-evaluated before making an investment decision. The contracting party for direct PV investments is mediplan Helm e.K., with personal liability of the owner pursuant to Sections 1, 17, and 19 of the German Commercial Code (HGB). For your specific situation, please consult a licensed tax advisor, attorney, or investment advisor. All information is provided without warranty. As of August 2026.
References
- Regulation on the Grid Connection of Power Plants (KraftNAV) — Scope of Application, Section 1, Paragraph 1
- § 118 EnWG — Exemption from grid fees for storage facilities, paragraph 6
- Regulation (EU) 2024/1747 — Article 19d, Bilateral Differential Contracts Effective July 17, 2027
- § 7g of the Income Tax Act (EStG ) — Investment Tax Credit and Special Depreciation
- Federal Network Agency — Requirements for the Maturity Assessment Process
- BDEW — Electricity Price Analysis, April 2026 (Industrial Electricity Prices for New Contracts) and Grid Connection Requests, November 2025
- Federal Court of Justice (BGH), Order of July 15, 2025, EnVR 1/24 — Capacity Allocation for Grid Connection
As of August 2026. Related posts: Grid Fees in 2026 and the AgNes Reform, PV with Battery Storage, CfD Requirement in 2027.
