In brief
Requests for transmission-grid connections have increased substantially in recent years, driven by rapid investment in the energy transition (including large-scale battery storage facilities and electrolyzers) and simultaneous growth in digital infrastructure such as data centers. As of the end of Q3 2025, the four German transmission system operators (TSOs) – 50Hertz, Amprion, TenneT, and TransnetBW – had received 717 grid connection applications totaling approximately 270 GW in requested capacity. Of those, 545 applications related to large-scale battery storage facilities (each with at least 1 MW of gross capacity), representing 211 GW of the overall requested volume. In addition, according to a survey of 17 distribution system operators conducted by the German Association of Energy and Water Industries (BDEW) and published on 27 November 2025, applications for an additional 569 GW of distribution-grid capacity had been submitted.
In more detail
The current first come, first served rule for allocating grid connection capacity, set out in Section 4 of the Power Plant Grid Connection Ordinance (KraftNAV), has created significant distortions in the market. Under this system, developers can reserve grid capacity for projects that are still at a very early stage and have little realistic prospect of being built, effectively blocking more advanced and viable projects from moving forward. In response, the four German TSOs have proposed a maturity based allocation framework (“first ready, first served”) in a joint concept paper issued on 5 February 2026. Their proposal shifts the focus toward project maturity and anticipated grid or system benefits when assigning capacity. This article provides an overview of the key elements of the proposed changes, which are expected to have particular impact on large energy users such as electrolyzers and data centers, as well as large scale battery storage facilities.
Current framework for transmission-grid connections
Under existing law, transmission-grid connection requests are processed on a first-come, first-served basis. This approach does not allow TSOs to prioritize applications using objective criteria. As a result, project developers may secure capacity for early stage or speculative projects, preventing more advanced and feasible projects from moving forward. Market participants have expressed concerns that capacity reservations may in some cases be made for speculative purposes.
Regulatory background
On 5 February 2026, the German TSOs jointly presented a new concept designed to enable more targeted and efficient processing of grid-connection applications. The proposal was prompted by amendments to the KraftNAV adopted in December 2025, which removed large-scale battery storage systems from the Ordinance’s scope. Consequently, there is currently no specific statutory procedure governing transmission-grid connection applications for battery storage facilities. Instead, such applications fall under Section 17 (1) of the Energy Industry Act (EnWG), which grants TSOs broad discretion to determine allocation procedures, provided that those procedures are appropriate, non-discriminatory, and transparent.
New procedure: annual cycles, minimum requirements, and maturity-based prioritization
Under the TSOs’ proposed maturity evaluation procedure, transmission grid connection applications would be reviewed in annual process cycles. During a designated information and application window, the responsible TSO would collect all submitted applications. Only applications meeting specified minimum requirements would be admitted into the evaluation. Admitted applications would then undergo a cluster study evaluating project maturity against defined criteria, including:
- Secured land rights and permitting status;
- Technical design of the facility and proposed connection concept;
- Applicant’s economic and financial standing; and
- Grid and system benefits.
The maturity score assigned to each project would determine its priority within the allocation process.
If eligible applications exceed available grid capacity, only the highest scoring projects would receive a grid connection offer. The offer would include a proposed implementation timeline. Once accepted — creating a binding capacity reservation — the TSO and applicant must negotiate a connection installation agreement and a grid connection agreement within three months. If the parties cannot reach agreement, the TSO may issue a unilateral negotiation schedule, which the applicant must accept within 14 days or risk losing the reservation. Failure to comply with agreed upon implementation milestones may also result in revocation of the reservation.
Applications that cannot be accommodated due to limited capacity may be rolled over to the next cycle free of charge.
Fees and treatment of existing applications
Each application would require payment of a EUR 50,000 application fee. Upon acceptance of a grid connection offer, the applicant must pay an implementation deposit of EUR 1,500 per MW, which is later credited against the construction cost contribution. The deposit would be forfeited only if the project fails for reasons within the applicant’s control.
Existing applications that already hold a capacity reservation will continue to be processed under the prior first come, first served system. All new applications still under review will be transitioned to the new process once the maturity evaluation framework is launched — currently expected in April 2026.
Outlook
The TSOs have submitted the new concept to the Federal Network Agency (BNetzA) for approval, particularly regarding compliance with Section 17(1) EnWG. BNetzA has not yet issued a position. Subject to approval, the new process may be implemented as early as April 2026.
The TSOs have also suggested that Section 17 EnWG be amended to further strengthen legal certainty. The Federal Ministry for Economic Affairs and Energy (BMWE) has incorporated the proposed principles into the recently leaked draft “grid package.”
Initially, the new maturity based procedure would apply to all transmission grid connection applications falling outside the scope of KraftNAV and the Renewable Energy Act (EEG) – primarily battery storage facilities and large electricity consumers such as data centers, industrial plants, and electrolyzers. Over the longer term, the TSOs view a uniform allocation framework covering both load and generation facilities, including conventional power plants and renewable energy installations, as desirable.
However, because the maturity evaluation system cannot assign priority to particular industries or technologies, it will not resolve the central issue of rising grid capacity demand — especially from digital infrastructure — outpacing short term expansion possibilities. Policymakers may therefore need to consider targeted policy instruments, such as technology specific capacity quotas.