Key takeaways

• The new grid fees unlock additional flexibility for load-shifting and trading, as a single peak no longer sets the annual bill: Sites consuming over 100 000 kWh only pay a volumetric penalty above their chosen capacity subscription level, meaning battery capacity will no longer focus primarily on reducing individual peaks year round.

• Arbitrage is exempt from grid fees, unlocking additional value from trading: Energy drawn charged from and later exported to the grid is free of fees if metered separately. As batteries pay less for the electricity they charge, trading is worthwhile in more quarter hours, since the necessary price-spread for arbitrage is reduced.

• Atypical network usage is retained only till 2032: Sites with consumption above 10 GWh, that previously qualified for the scheme before 2027 and had an average consumption above 10 GWh can receive their existing privileges until 2032.

• Value uplift from dynamic grid fees are delayed until 2030 - 2033: The regulator will finalise them in a separate decision for batteries above medium voltage.

The Federal Regulator (Bundesnetzagentur) published its draft on 6 August 2026. The consultation was closed on 18 September, and the final decision is planned for the end of 2026. The contents shared below are preliminary and potentially subject to change.

1. Additional flexibility is unlocked through the new grid fee model 

Today, the highest annual quarter-hour of grid draws sets the capacity price a site pays per year. Reducing the peak is the main priority, so most batteries are used exclusively for peak shaving.

In the planned model, a site orders a capacity per year and pays a cost per kW ordered. Energy withdrawn from the grid within that capacity costs the standard volumetric fee, AP1. The kilowatthours above the set threshold are billed at a higher AP2, which costs 200–350% of AP1. A single overshoot becomes a marginal additional cost, not a year-long penalty.

The new model changes the battery operations: The system is no longer limited to prioritising peak-shaving. Given a sufficient price signal, the battery can combine load shifting with trading and arbitrage. Especially under the new MiSpeL ruleset, batteries can charge from the grid and PV electricity without losing their subsidies for volumes exported to the grid. Setting the right capacity is key, but it is now one lever among several. Prices only become known with the first price sheets in October 2028.

2. Trading is exempt from grid fees 

Electricity charged from and exported into the grid is exempt from the volumetric charges, provided these volumes can be separated by metering. Capacity charges still apply. It will likely follow the MiSpeL rules, but this is yet to be confirmed.

This unlocks additional flexibility for trading, since batteries pay less for the electricity they charge, meaning they can profitably conduct arbitrage with a lower price spread.

3. Atypical network usage to be phased out and the uplift from dynamic grid fees is delayed

• Atypical network usage: Sites with consumption above 10 GWh can temporarily remain in the scheme until the end of 2031, provided they had a valid agreement with their grid operator by end of 2028, met the discount conditions at least once in 2026–2028, and averaged more than 10 GWh between 2024–2027. The scheme allows sites to pay a reduced grid fee if their peak demand falls reliably outside the quarter-hours where the grid is busiest. 

• Dynamic grid fees for storage: Batteries connected at medium voltage or above shall receive dynamic grid fees from 2030 and 2033, but this will be finalised in a separate decision by the Federal Regulator. The dynamic grid fees provide price incentives for storage to use their flexibility to reduce local congestion and redispatch.
  
  

4. Regulatory changes unlock new opportunities, but require a partner to handle the added complexity

The new grid fees raise the bar for C&I battery optimisation. From 2029, simple peak-shaving creates far less value as the upside increasingly moves towards load shifting and trading.

Alongside the changes with MiSpeL, companies planning or operating C&I batteries need a partner who can navigate the complexity to maximise the systems value.  

Reach out and learn what is possible at your sites!