An alliance of 11 German associations representing the energy, housing, real estate and skilled trades sectors has urged the Federal Network Agency to scrap a proposed grid surcharge on solar prosumers, warning it could undermine rooftop solar economics, deter investment and slow Germany’s solar expansion.
A legal opinion commissioned by the German Solar Association (BSW-Solar) has also questioned the surcharge’s legality, citing potential conflicts with EU law and constitutional protections for existing solar installations.
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The proposed surcharge forms part of a wider debate over electricity grid charges, including whether households that generate and consume their own solar power should contribute more towards grid costs, irrespective of the grid capacity they actually use.
The associations argue that such a system could increase costs for solar households and weaken the financial case for installing new systems. The impact could be compounded by planned reductions in solar power subsidies by the German federal government.
Germany plans electricity grid fee reform from 2029
From 1 January 2029, Germany is set to introduce a reformed electricity grid charging system under the Federal Network Agency’s AgNes process, aimed at redistributing network costs among consumers, solar prosumers, electricity generators and storage operators.
The regulator published its draft reform in August 2026, with a final decision planned by the end of the year.
Under the proposal, households that generate and consume their own solar power would pay a higher annual fixed grid charge, with additional costs expected to vary by region but remain below €100 per year.
Plug-in balcony solar systems would be exempt. Electricity generators would also face a proposed capacity-based grid fee of €4-7/kW per year, while existing installations would receive a 20-year exemption from their commissioning date.
The reform also proposes capacity-based charges for battery storage, although home storage systems connected to low-voltage networks would remain exempt.
For industrial consumers, the reform would replace existing capacity charging arrangements for large users with a system combining capacity-based fees and additional charges when contracted capacity is exceeded.
Existing arrangements for certain industrial users would be retained during a transition period, with further decisions on future tariffs expected in 2027.
Legal concerns over proposed surcharge
In an expert opinion commissioned by BSW-Solar, lawyer and honorary professor Dörte Fouquet identified potential legal issues with the planned surcharge.
According to the associations, the proposal may conflict with EU law requirements that grid financing reflect the costs attributable to users. It also raises concerns over the principle of equal treatment and the constitutional protection of legitimate expectations for operators of existing installations.
“Anyone who invests in their own solar system or battery storage system must not be punished with additional fees. Grid fees should be based on how much the power grid is actually used – and not on whether someone generates solar power on their own roof,” explains Carsten Körnig, managing director of the German Solar Industry Association (BSW-Solar).
“Germany needs more solar roofs, battery storage and intelligent use of the power grids – no new financial hurdles for the modernisation of our energy supply in the electricity, heat and mobility sectors,” said Körnig.
The legal assessment adds to industry opposition to the proposed reform, although the cited concerns do not in themselves establish that the surcharge would be unlawful.
Industry calls for cost-based grid charges
Rather than imposing an additional charge on self-consuming solar operators irrespective of their actual use of the grid, the associations are calling for grid costs to be allocated on a fair and cost-reflective basis.
If solar system operators are required to make an additional contribution, the groups argue, charges should be linked to the agreed grid feed-in capacity. They are also demanding grandfathering protections for existing installations to prevent operators from facing new financial conditions after investing under the current framework.
In 2025, Germany approved legislation aimed at curbing solar power surpluses and negative electricity prices by ending feed-in tariff payments for new PV installations during periods of negative pricing.
The rules also introduced a 60% cap on grid feed-in for certain new systems without smart meters, while encouraging greater self-consumption and battery storage.
