PV systems over 20 years old: What happens after the end of EEG 2023 funding?

Brief overview

• systems older than 20 years are photovoltaic systems whose 20-year EEG funding period pursuant to Section 25 of the EEG has expired – the fixed feed-in tariff or market premium automatically ceases with the anniversary of commissioning.
• In 2026 alone, more than 66,000 PV systems in Germany will lose their EEG subsidies—and this trend is set to grow as further vintages follow annually starting in 2027.
• Generally, there is no charge for commercial PV systems over 20 years old with an output exceeding 100 kWp the grid operator's automatic feed-in tariff: You must switch to other direct marketing (§ 21a EEG) or a PPA.
• There is no obligation to decommission – continued economic operation is possible and sensible in most cases, as the plant technology is usually fully functional after 20 years.
• The EEG 2027 does not change existing post-20 regulations, but is relevant for the repowering decision: new plants as of January 1, 2027 will fall under a new support system featuring auctions and a reference market value mechanism (CfD) instead of a fixed feed-in tariff.

What are post-20-year PV systems?

"Ü20 systems" refers to photovoltaic systems whose entitlement to support under the Renewable Energy Sources Act has expired. Pursuant to Section 25 of the EEG, the market premium, the future refinancing contribution, or the free-of-charge feed-in is generally paid for 20 calendar years plus the year of commissioning—after which the entitlement expires automatically, regardless of the technical condition of the system. This basic 20-year rule remains unchanged in Section 25, Paragraph 1 of the government draft for the EEG 2027.

Since 2021, those affected are successively the first cohorts the major wave of expansion under the EEG 2000/2004. For commercial operators, this is no minor issue: Solar and ground-mounted systems from the early 2000s, which are now scheduled to lose their subsidies, often fall precisely into the size category (>100 kWp) for which automatic feed-in tariffs do not apply.

What are the legal implications when EEG subsidies expire?

The elimination of the subsidy means not the end of the plant's operation—the plant may continue to generate electricity; only the way the electricity is sold will change.

Systems over 20 years old up to 100 kWp

For them, the legislature has, through the Solar package I created a temporary follow-up regulation, which in the meantime extended through December 31, 2032 The grid operator automatically compensates the fed-in electricity at the annual market value for solar power, minus marketing costs, capped at a maximum of 10 ct/kWh (Section 23b EEG). In 2025, for example, the net value was approximately 3.8 to 4.3 ct/kWh. No separate agreement is required for this. The “until 2032” deadline itself is systematically reworded in the government’s draft of the EEG 2027 and will henceforth be enshrined in Section 25(3) of the EEG 2027, rather than appearing in the transitional provisions as it has until now—this does not change the substance of the provision.

Over-20 systems exceeding 100 kWp

For these – and thus for the majority of commercially relevant existing plants – the feed-in tariff applies not automatically. They are on the other direct marketing in accordance with Section 21a of the EEG. In this case, a direct marketer sells the electricity on the exchange without being entitled to EEG subsidies or a market premium. Guarantees of origin can also be marketed.

However, certain technical requirements remain in place: For systems between 25 and 100 kWp participating in voluntary direct marketing, the requirement for remote controllability under Section 10b of the EEG 2023 continues to apply. The government’s draft of the EEG 2027 tightens this requirement for systems under direct marketing New installationsThe previous 25 kW de minimis limit is eliminated, meaning that in the future, all directly marketed new systems must be technically remotely controllable regardless of their capacity (§ 10b paragraph 1 EEG 2027). For existing post-20-year (Ü20) systems as grandfathered systems, this does not change the previous obligation. The grid connection itself remains unchanged.

A Comparison of Options for PV Systems Over 20 kW

A complete dismantling of a post-20-year PV system is generally the economically least favorable option, as this can incur costs of about €100–250/kWp. It is primarily necessary if the system is no longer repairable due to a total technical failure. If, on the other hand, the system is still functional, negotiations with the subsequent tenant or a new owner can be worthwhile even if the location is given up.

The EEG 2027 is a turning point for post-20 operators as well.

For existing over-20-year installations, the government draft for the EEG 2027 initially changes nothing—the described regulations on feed-in remuneration (§ 23b, § 25 paragraph 3 EEG 2027) and other direct marketing (§ 21a EEG) continue unchanged, as these are existing installations. However, the reform becomes relevant the moment a Repowering is being considered. A newly constructed facility is automatically subject to the support system planned as of January 1, 2027, and no longer to the traditional fixed feed-in tariff.

Approval by the Bundestag is still pending

The Federal Cabinet adopted the government draft of the Renewable Energy Sources Act (EEG) 2027 on July 29, 2026, together with the grid connection package. It has been in the Bundesrat as federal council document 470/26 since August 14, 2026, and the next plenary session is scheduled for September 25, 2026; a reading in the Bundestag has not yet taken place. The law also requires state aid approval by the EU Commission, as the approval for the current EEG 2023 expires on December 31, 2026. Details may still change until the planned entry into force on January 1, 2027.

Refinancing contributions through CfDs

For commercial systems, repowering mainly involves the new Refinancing contribution (§ 21d EEG 2027) relevant: The government draft stipulates that in future, all subsidized systems with an installed capacity of 100 kW or more will have to pay revenues above the strike price in high-price phases via a two-way contract for difference (CfD) – supplementing the existing floating market premium, not replacing it. We have detailed this mechanism in our article on the EEG 2027 & Grid Package: Cabinet Decision on the Refinancing Contribution (CfD) at a Glance described.

Deadlines for over-20-year PV systems during expansion and repowering

For repowering or expansion decisions, this results in temporal levers. Who before January 1, 2027 receives an auction award for a planned repowering or extended post-EEG (Ü20) installation still secures the familiar conditions of the current EEG 2023 without a refinancing contribution. Anyone who receives the award after that should plan from the beginning with revenue skimming pursuant to Section 21d of the EEG 2027 and the new subsidy logic. Since, at the time of publication of this report, this is still a government draft that requires the approval of the Bundestag, Bundesrat, and the EU Commission, this timing consideration should be communicated with reservation until final adoption.

Recommendations for operators of commercial post-subsidy renewable energy plants

1. Check funding situation early: Clarify the system size, commissioning date, and associated options (feed-in tariff vs. obligation to direct-sell) in good time before the 20 years expire.
2. Calculate the cost-effectiveness of the options: Other forms of direct marketing, PPAs, and self-consumption optimization differ significantly in economic viability depending on the consumption profile at the site.
3. Evaluate technical condition: Inverter remaining service life, cabling, and module performance determine whether continued operation or repowering is the more sensible option.
4. Evaluate energy storage retrofitting as a lever for preserving value: A retrofitted battery storage system increases the self-consumption rate and creates additional sources of revenue (e.g. Redispatch, Control energy) – precisely when the feed-in tariff is abolished, the Self-consumption optimization in importance.
5. Align repowering timing with the draft EEG 2027: In the case of planned repowering, weigh up in good time whether commissioning under the current EEG 2023 or only under the planned refinancing contribution (§ 21d EEG 2027) makes more sense – and keep an eye on the status of legislation up to the reading in the Bundestag.
6. Keep track of deadlines and reporting obligations: Register the change of the marketing model with the network operator and, if necessary, commission new metering concepts in good time to avoid losses in revenue.

Frequently Asked Questions