Solar Package 1: What Changes for PV Investors and Businesses?
Solar Package 1 reduces red tape and increases feed-in tariffs for commercial photovoltaic systems—but the most important improvements for investors remain subject to EU state aid approval. What’s already in effect and what’s still pending—as of July 2026.
The short answer
Solar Package 1 is a legislative package designed to accelerate the expansion of photovoltaics, which took effect on May 16, 2024. For businesses and investors, it brings two key benefits: First, immediate reductions in red tape—higher thresholds for system certification, simpler grid connection, and more flexible direct marketing. Second, four significant improvements that are still subject to EU state aid approval and may not be implemented as of July 2026: the 1.5 ct/kWh premium for commercial rooftops, larger open-space auctions, the repowering update, and a segment for special solar installations. Their implementation depends on the EEG 2027.
This article is intended for PV investors and businesses that want to know what changes Solar Package 1 is already bringing about today and what will take effect with the EEG 2027. Solar Package 1 is the biggest step yet toward reducing red tape for the photovoltaic sector—and it’s doubly relevant for commercial PV investors. It reduces the effort involved in certification, grid connection, and marketing, while also raising the feed-in tariff for larger rooftop systems. The catch: the very provisions that impact returns have not yet taken effect. Anyone investing in 2026 needs to know which rules already apply and which will take effect only with the EEG 2027. The guide to EEG feed-in tariffs for 2026 shows what the current rates look like today.
What is Solar Package 1?
Above all, the package amends the Renewable Energy Sources Act (EEG) and the Energy Industry Act (EnWG). The Bundestag and Bundesrat passed the legislative amendments in April 2024; with these changes, the federal government aims to accelerate the expansion of solar power as a key step in the energy transition. The package covers the entire spectrum of solar energy: from plug-in solar devices to commercial rooftop systems of all capacity classes and community-based building power supply, all the way to large ground-mounted systems. From a B2B perspective, three key areas are particularly important: remuneration for commercial rooftops, the reduction of red tape in certification and grid connection, and the expansion of open-field tenders.
Solar Package 1 took effect on May 16, 2024.
Important for context: Solar Package 1 is not a law that will take effect in the future; it has been in force for two years—albeit with one crucial restriction. To date, Germany has been unable to implement several key provisions because the European Commission has made its approval under state aid law contingent on certain conditions. It is precisely this distinction between “already in effect” and “subject to conditions” that is the most important message for investors.
On that day, Solar Package 1 took effect (published in the Federal Law Gazette on May 15, 2024).
A subsidy for commercial rooftop systems of 40 kW or more — though it is still subject to EU state aid approval.
On this day, the EU state aid approval for the current EEG expires—setting the stage for the EEG 2027.
How does Solar Package 1 affect investors and businesses?
The following overview distinguishes between the two levels. It serves as the primary guide for any investment decision related to Solar Package 1.
A higher threshold for renewable energy certificates, simplified grid connection for systems up to 30 kW, more flexible direct marketing for systems up to 200 kW, and shared building power supply. These measures have an immediate impact on the timeline and utility bills.
Commercial rooftop surcharge of +1.5 ct/kWh, open-space bids up to 50 MW, repowering incentives for rooftops, and a sub-segment for special solar installations. These measures will not take effect until the EEG 2027.
| Action | Impact on Investors/Businesses | Status (July 2026) |
|---|---|---|
| Investment Certificate Threshold Raised | Reduced certification effort and costs for larger facilities | Effective as of May 16, 2024 |
| Simplified Grid Connection (up to 30 kW) | Faster connection, expanded simplified procedure | Effective as of May 16, 2024 |
| Direct Sales Made More Flexible (up to 200 kW) | Donate Surplus Goods for Free Instead of Selling Them | Effective as of May 16, 2024 |
| Community Building Utility Services (Section 42b of the Energy Economy Act) | Simplified Electricity Distribution Within the Building | Effective as of May 16, 2024 |
| Commercial Roof Surcharge +1.5 ct/kWh (40 kW and above) | Higher Feed-in Tariff for Commercial Rooftop Systems | Reservation Regarding Subsidies |
| Open Space: Maximum bid size 20 → 50 MW | Larger solar farms possible per bid | Reservation Regarding Subsidies |
| Improvements in the Repowering of Rooftop Systems | Module Replacement Without Loss of Entitlement to Compensation | Reservation Regarding Subsidies |
| "Special Solar Systems" Subsegment | Separate Call for Proposals for Agricultural, Parking Lot, Floating, and Moor PV Projects | Reservation Regarding Subsidies |
| Source: BMWE — FAQs and Overview of Solar Package I; DGRV — Update on State Aid Approval (November 18, 2025). | ||
The 1.5-ct surcharge for commercial roofs — and why it hasn't been implemented yet
For investors, this is the most important point: The surcharge is provided for in the law but does not yet affect revenues. Anyone calculating the costs of a commercial rooftop system today must use the current rates without the 1.5 ct—and, if anything, factor in the surcharge as a potential opportunity, not as a guaranteed amount. The rates currently in effect are listed in the Guide to EEG Remuneration 2026.
Beyond the rate itself, the solar package also strengthens the tendering process for large rooftop PV systems: The annual volume will increase to 2.3 GW starting in 2026, and after a one-year transition period, the threshold for mandatory tendering will drop to 750 kW. The premium itself—1.5 cents per kilowatt-hour—will remain excluded until EU approval is granted.
| Equipment segment | Partial injection | Full feed-in |
|---|---|---|
| 10–40 kWp (pro rata) | 6.66 cents per kWh | 10.24 ct/kWh |
| 40–100 kWp (pro-rata) | 5.44 ct/kWh | 10.24 ct/kWh |
| Solar Package Surcharge for 40 kW–1 MW | not yet in effect | not yet in effect |
| Source: Federal Network Agency (EEG feed-in tariffs, valid August 1, 2026–December 31, 2026). No further reduction phase has been scheduled; the EEG 2023 remains in effect through December 31, 2026 (Section 49 EEG). | ||
Less red tape: Plant certificate, grid connection, direct sales
For a long time, the system certificate was a cost driver and a risk to the schedule for medium-voltage connections: expensive, time-consuming, and, most recently, subject to delays at the certification bodies. Because Solar Package 1 significantly raises the threshold, many commercial rooftop and ground-mounted systems are no longer subject to the full certification requirement; below this threshold, simplified verification via unit certificates is sufficient. This shortens the time to commissioning.
Lower bureaucratic hurdles for grid connection also take effect immediately: The simplified procedure now applies to systems up to 30 kW, instead of the previous 10.8 kW; further simplifications are planned for systems up to 100 kW. Grid operators must provide a digital connection portal for registration; if they do not respond to the grid connection request within one month, systems up to 30 kW may be connected even without express consent (Section 8 of the Renewable Energy Sources Act (EEG)). And operators of systems up to 200 kW with high self-consumption—for whom direct marketing is not cost-effective—have been able, since the Solar Package 1, to transfer their surplus electricity to the grid operator without incurring direct marketing costs, rather than marketing it at their own expense. The analysis of direct marketing of PV electricity provides a more in-depth look at how direct marketing typically works.
Open Spaces and Special Solar Installations
For investors focused on open-field projects, Solar Package 1 shifts the parameters. The higher bid cap allows for larger individual projects without a tender process as soon as EU approval is granted. The dedicated sub-segment for specialized solar installations creates a protected competitive framework for agri-PV and similar projects, which would otherwise have to compete against more affordable standard open-field sites. The article on Agri-PV as an investment delves deeper into the economic rationale behind Agri-PV as an investment opportunity.
At the same time, the package ties the expansion of open-space areas to minimum criteria for nature conservation and, in principle, makes disadvantaged agricultural areas eligible for funding—with an opt-out option for the states. Until approval is granted under state aid law, the previous quantity and size limits will continue to apply to the bidding processes—the Federal Network Agency will conduct the bidding rounds unchanged in accordance with the old law.
For agri-PV investors, there is an additional political risk: The draft bill for the EEG 2027 (as of April 21, 2026) proposes to eliminate the sub-segment for special solar installations (Section 37d EEG) entirely—even before it has ever been implemented. It therefore remains unclear whether this part of Solar Package 1 will ever take effect. This underscores the central point: Solar Package subsidies that are still subject to conditions do not belong in a robust return-on-investment calculation.
Balcony Solar Panels, Tenant-Generated Electricity, and Community Participation
For investors, this part is of secondary importance, but it illustrates the breadth of the package. Tenant electricity is more relevant for businesses: Solar Package 1 now also supports it on commercial buildings and their ancillary facilities, such as garages, as long as the electricity flows without being fed into the grid. Together with the communal building power supply under Section 42b of the Energy Industry Act (EnWG)—in which consumption is measured every quarter hour and allocated to participants in 15-minute intervals—new, less bureaucratic ways are emerging to use solar power directly in buildings and ancillary facilities.
State Aid Reservation and the EEG 2027: The Timeline
This connection is crucial because it links two areas of focus. The current EEG subsidy approval expires on December 31, 2026; at the same time, the Commission is requiring the clawback mechanism as a condition for approving the Solar Package surcharges. The EEG 2027 is intended to resolve both issues. If this amendment is delayed, the payment of the commercial rooftop surcharge will also be delayed. This is doubly tricky for investors: The EEG 2027 could not only activate individual Solar Package provisions but also modify or eliminate them—the draft bill, for example, calls for the elimination of the “special solar installations” sub-segment. The article on the CfD requirement starting in 2027 explains how the planned system change to two-sided difference contracts will affect revenues.
| Stage | Date | Status |
|---|---|---|
| Solar Package 1 Takes Effect | 16.05.2024 | Done |
| Four Core Regulations Subject to State Aid Review | since May 16, 2024 | open |
| EEG subsidy approval is set to expire | 31.12.2026 | strict EU deadline |
| EEG 2027 with a cap mechanism | Target Date: January 1, 2027 | Draft bill, not yet adopted |
| Activation of the surcharges as early as possible | Mid-2027 | Depending on the EEG 2027 |
| Source: DGRV (Nov. 18, 2025); BMWE — FAQs on Solar Package I; Prometheus Law Firm (EEG 2027, 2026). | ||
What Solar Package 1 Means for Your Investment Decision
Specifically, this means three things. First: Anyone planning a commercial rooftop system should actively take advantage of the certification and connection simplifications, as they have an immediate impact on the timeline and ancillary costs. Second: Return-on-investment calculations that already factor in the commercial rooftop surcharge are too optimistic until EU approval is granted—a robust analysis excludes the 1.5 ct. Third: For ground-mounted and agri-PV projects, it’s worth checking the status of approvals, because higher bids and the special segment only take effect afterward.
Direct investments in photovoltaics through the Helm Group continue to yield a 6–10 percent annual return before taxes (2024 portfolio data); with tax benefits from the investment deduction and depreciation, returns of up to 10–12 percent are possible. This return range makes the investment viable regardless of whether the solar package subsidy is paid out at the end of 2027. The guide to photovoltaic investments provides an overview of opportunities, risks, and tax benefits.
Break Down Solar Package 1 for Your Project
Whether a rule applies now or not until 2027—we’ll explain what Solar Package 1 means for your specific rooftop or ground-mounted system. Thanks to the personal liability of mediplan Helm e.K.’s owner, this is a well-founded assessment, not just an anonymous consultation.
Frequently Asked Questions (FAQ)
What is Solar Package 1, explained simply?
Solar Package 1 is a legislative package designed to accelerate the expansion of photovoltaics; it has been in effect since May 16, 2024. It reduces red tape related to certification, grid connection, and marketing; increases the feed-in tariff for commercial rooftops; and strengthens solar farms. However, several key provisions are still subject to EU state aid review.
Does the 1.5-ct surcharge from Solar Package 1 already apply?
No. The 1.5 ct/kWh surcharge for commercial rooftop systems of 40 kW or more is subject to EU state aid approval and, as of July 2026, is not included in the payment rates. Its implementation depends on the EEG 2027 and is not expected until mid-2027 at the earliest.
Which Solar Package 1 regulations are already in effect?
The rules aimed at reducing bureaucracy take effect immediately: the higher threshold for installation certificates (270 kW of feed-in capacity or 500 kW of installed capacity), the simplified grid connection procedure for systems up to 30 kW, the more flexible direct marketing options for systems up to 200 kW, and community-based building energy supply under Section 42b of the Energy Industry Act (EnWG).
What does the state aid reservation mean, specifically?
The state aid reservation means that a regulation enacted by law may not be implemented until it has been approved by the European Commission. With regard to Solar Package 1, the Commission is requiring a mechanism to recapture excess revenues. Until this mechanism is enshrined in the EEG 2027, four key provisions of the package remain suspended.
How does Solar Package 1 affect businesses that generate their own electricity?
Little will change for self-consumption, as solar power used for personal consumption is not compensated under the EEG. However, businesses will benefit from faster grid connection, less certification effort, and shared building power supply. The key economic benefit remains the reduction in electricity purchased from the grid.
What is communal building services?
Community building energy supply under Section 42b of the Energy Industry Act (EnWG) is a simplified model introduced by Solar Package 1: Solar power generated on the roof is distributed directly to multiple consumers in the same building without the full obligations of an energy supplier. It complements and simplifies the traditional tenant electricity model.
Conclusion: Two Speeds
Solar Package 1 brings mixed news for PV investors and businesses: The reduction in red tape takes effect immediately and lowers actual costs, while the surcharges that affect returns are still awaiting EU approval two years after the package takes effect. Those investing in 2026 will base their calculations on today’s rates, take advantage of the streamlined procedures, and treat the 1.5-cent surcharge as an opportunity rather than a basis for calculation.
For further reading: The “Guide to EEG Remuneration 2026” explains the current rates; the article on the CfD requirement starting in 2027 discusses the upcoming system change; and the “Overview of Photovoltaic Investment” shows how a direct PV investment works in practice.
References
- BMWE — Solar Package I (Overview of Measures)
- BMWE — FAQs on Solar Package I (as of April 2025)
- DGRV — Update on the State Aid Approval of Solar Package I · November 18, 2025
- pv magazine — Solar Package 1 takes effect on May 16, 2024 · May 15, 2024
- Federal Network Agency — EEG Subsidies and Subsidy Rates
- Laws on the Internet — Section 42b of the Energy Industry Act (EnWG) (Community Building Supply)
- Laws on the Internet — Section 8 of the Renewable Energy Act (EEG) (Grid Connection, Simplified Procedure)
- Prometheus Law Firm — EEG 2027
Related Articles: CfD Requirement for PV Investors Starting in 2027 · EEG Feed-in Tariff 2026
