TSO implementation concept

In accordance with Section 13k(6) of the Energy Industry Act (EnWG) – ‘Utilisation instead of curtailment’ – transmission system operators (TSOs) are required to develop an implementation plan by 1 April 2024. This plan is intended to define the key framework conditions for this instrument.

The TSOs, in consultation with the relevant stakeholders, drew up the implementation plan within the deadline and submitted it to the Federal Network Agency (BNetzA) for review in accordance with Section 13k(7) of the Energy Act (EnWG). The BNetzA has completed its review and concluded that the specific design of the submitted implementation plan for the trial phase is suitable for effectively reducing the curtailment of electricity from installations in accordance with Section 3(1) of the Renewable Energy Sources Act and does not compromise grid and system security. There are no substantive objections.

Implementation plan for the target model

On 1 October 2026, following the conclusion of the two-year trial phase, the target model for the ‘Benefit instead of curtailment’ instrument will come into force in accordance with Section 13k of the Energy Industry Act (EnWG). To this end, the findings from the trial phase have been incorporated into the new Implementation Plan v2.0. The adjustments include editorial corrections, the incorporation of the tender design and an adjustment of the remuneration framework, taking into account the findings from the trial phase, as well as an update of the relief regions.

The TSOs, in consultation with the relevant stakeholders, revised the implementation concept within the deadline and submitted it to the Federal Network Agency (BNetzA) for review in accordance with Section 13k(7) of the Energy Act (EnWG). The BNetzA has completed its review, concluding that the specific design of the submitted implementation concept for the target phase is suitable for effectively reducing the curtailment of electricity from installations in accordance with Section 3(1) of the Renewable Energy Sources Act and does not compromise grid and system security. There are no substantive objections.

The resulting necessary amendments to the contractual documents will be published on 1 July 2026.

The current implementation plan is valid only for the duration of the trial phase (from 1 October 2024 to 30 September 2026 in accordance with Section 13k(1) of the Energy Industry Act).

The implementation concept has been drawn up with the best possible involvement and participation of the relevant stakeholders. In drawing up the concept, the TSOs did not confine themselves to the minimum requirements of Section 13k of the Energy Industry Act (EnWG), but actively engaged with the industry to gather relevant perspectives on the subject. These were incorporated into the implementation concept to create the best possible framework for successful implementation.

Furthermore, the TSOs commissioned Frontier Economics Ltd. to review the remuneration framework they had proposed in an expert report. Frontier Economics Ltd. concluded that the submitted concept is in line with the objectives of Section 13k of the EnWG and that economic and energy industry aspects are appropriately taken into account.

To enable potential participants to assess the business case for taking part, a template is available for download below. This template allows you to independently calculate the individual SNK compensation as described in the remuneration framework of the TSO Implementation Concept.

Please note that this template is provided for guidance only and is therefore non-binding and provided without warranty.