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Solar Package I: Critical points still blocked

Although the Solar Package I has offered enhancements for balcony power plants since 2024, the EU Commission is blocking central subsidies for commercial and agri-PV. The reason is the dispute over contract-for-difference (CfD) mechanisms, without which higher remuneration rates and bid sizes (up to 50 MW) cannot come into force for the time being.

With the Solar package I In May 2024, one of the most comprehensive reforms of the Renewable Energy Sources Act (EEG) to date was passed by the then traffic light coalition in Germany. The goal was to significantly accelerate the expansion of photovoltaics and remove existing hurdles. The law addressed a broad spectrum: from balcony power plants and tenant electricity to larger rooftop installations and ground-mounted projects. While some simplifications came into effect immediately, others central funding elements further subject to subsidy law approval by the European Commission.

Existing Regulations & Reliefs According to the Solar Package I

Individual measures of the Solar Package have been effective since May 2024, primarily for smaller PV systems Reliefs

  • Balcony power plants may now be operated with up to 800 W. Registration with the grid operator is no longer required; registration in the market master data register is sufficient.
  • Network connection requests were accelerated: For systems up to 30 kWp A four-week period applies, after which the connection is considered approved.
  • Repowering from roof systems was fundamentally made possible, provided that no additional compensation increase occurs.

Pending state aid approval by the EU blocks critical points

The EU Commission has so far No authorization for the central funding elements of the Solar Package I, have been issued. Primarily affected are:

  • the Increase in feed-in tariff at 1.5 ct/kWh for systems from 40 kW,
  • the Increase in maximum bid size for open-space facilities from 20 MW to 50 MW,
  • the increased feed-in tariff for agri-photovoltaics, parking lot, moor, and commercial rooftop systems,
  • precise wording of the regulations for the Repowering larger projects with salary increase,
  • simplified regulations for Customer Systems & Tenant Electricity. The so-called customer system privilege according to § 3 No. 24a EnWG in Germany is still in the way of this.

For many of these open points, the Commission's demand to introduce a recovery mechanism, for example in the form of Contracts for Difference (CfD) on the way. This is intended to skim off unexpected additional revenue during high-price phases. Since Germany has not yet implemented this mechanism, approval is significantly delayed.

Impacts and Market Reaction of the Blocked Points of the Solar Package I

The blockade on EU approval is leading to significant uncertainties in the industry, even though the ongoing EnWG legislative process already includes improvements:

  • Operators and investors cannot claim central subsidies because the old EEG (Renewable Energy Sources Act) regulation from 2023 is valid until further notice.
  • Many projects, particularly in the Agri-PV sector, are on hold or are not connected to the grid despite being completed, because the calculations are not viable without the new remuneration rates.
  • Project developers face a double risk: delays in implementation and uncertainty as to whether the planned higher remuneration will apply retroactively.

Industry circles are now talking about a „standoff“ that could massively slow down the planned expansion of photovoltaics.

Outlook & Conclusion

A binding schedule for state aid approval by the EU is not yet available. Negotiations between the German federal government and the Commission are proving difficult, and failure is increasingly considered possible. Should the EU insist on a CfD mechanism, another amendment to the law would be necessary.

With that, the Solar Package I stands between ambition and reality: while smaller relief measures are already taking effect, the central financial incentives blocked. For the expansion of photovoltaics in Germany, this means planning uncertainty, postponed investments, and the risk that urgently needed projects cannot be implemented in time.

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