Grid fees for battery storage: exemption, AgNes reform and costs from 2029

Brief overview

• Today: New battery storage systems that become operational by August 4, 2029, are exempt from the network charges for electricity supply for 20 years from the start of operation pursuant to § 118, paragraph 6 of the EnWG.
• From 2029: The Federal Network Agency (BNetzA) plans to introduce a network tariff for new grid-connected storage systems with the NetEntgelt Reform AgNes. This tariff is based solely on the network connection capacity (capacity price in €/kW). Labor costs, as in the new NetEntgelt Basic System, are not included for battery storage systems. Therefore, there is no double burden for charging and discharging.
• Asset protection: According to the regulatory draft of August 6, 2026, the exemption holder who makes the final investment decision (FID) before January 1, 2027, demonstrates it by March 31, 2027, and puts the storage into operation by August 4, 2029.
• Costs without protection of the investment: According to the BNetzA, the capacity price is approximately €4 to €7 per kW of contracted grid connection capacity per year. At 10 MW, this amounts to around €40,000 to €70,000 per year.
• Important: The draft regulation has not yet been finalized. The BNetzA intends to issue the regulation in 2026.

Grid fees are among the cost blocks that determine the profitability of a battery storage system. A storage system absorbs large amounts of electricity from the grid and feeds it back into the grid later. Without special regulations, it would be taxed like a final consumer for this. Exactly this is prevented by the legal exemption in § 118(6) of the EnWG. The reform of the grid fee system (AgNes) will, however, redraw this framework. This article explains what currently applies, what the BNetzA plans to do from 2029 onwards, who retains grid protection, and what grid fees may be applied to new battery storage systems.

The applicable legal situation: § 118, paragraph 6, EnWG

According to § 118(6) of the EnWG, installations for the storage of electrical energy are exempt from the network charges for electricity for 20 years from commissioning, if they are put into operation within 18 years from August 4, 2011. The commissioning window thus ends on August 4, 2029.

Requirements and scope:

• Re-feeding into the same network: The electricity that is drawn from the grid is freed up; it is stored and fed back into the same grid at a later time.
• Mixed-use storage: With the EnWG amendment, which the Bundestag adopted on November 13, 2025 and which has been in effect since December 23, 2025, the exemption is formulated as a „to the extent“ regime. It applies insofar as the electricity drawn from the grid is again fed into the grid. Storage facilities operating in a mixed mode that consume part of the electricity locally are thus partially exempt.
• Measurement and reporting obligations: The amendment also refers to § 21 of the EnFG. The proportional exemption therefore applies to measurement, demarcation, and reporting obligations, as are known from the storage allocation benefits. Whether this also applies to pure standalone storage is open to interpretation. A law firm specializing in energy law sees a relevant risk that the requirements will also apply there. Operators and marketers should therefore coordinate with the network operator regarding measurement concepts and reporting deadlines.
• Only network charges: The exemption applies to the network charges themselves. Taxes and electricity taxes follow their own regulations and are not included in it.
• Authority to deviate from the regulations: Section 118, paragraph 6 of the EnWG grants the regulatory authority the option to deviate from the statutory exemption by means of a determination. The BNetzA makes use of this in the AgNes procedure.

AgNes: What will change starting in 2029

The trigger for the reform is a judgment of the European Court of Justice of 2 September 2021 (Rs. C-718/18). According to that judgment, the net charging regulation may not be implemented by government decree but must be submitted to the independent regulatory authority. The StromNEV therefore expires on 31 December 2028. In the proceedings, the BNetzA is submitting AgNes (General Network Fee System for Electricity) the successor regulations are fixed, which are to take effect as of January 1, 2029.

Status of proceedings:

• January 2026: In an orientation paper, the BNetzA fundamentally questions the exemption from network charges for storage.
• May 27, 2026: In the preliminary status quo, the BNetzA deviates from this and prioritizes trust protection higher.
• August 6, 2026: The BNetzA is publishing the complete draft of the regulations (198 pages) for consultation.
• September 18, 2026: The consultation period has ended.
• Still 2026: The decision to establish the deadline has been announced; the BNetzA has not yet announced a date.

The new basic system and the role of the memory: For larger consumers, the grid fee in the new system consists of a capacity price for the capacity ordered annually and two labor costs. Labor cost 1 (AP1) applies within the ordered capacity, labor cost 2 (AP2) over it, and is 200 to 350 % of AP1. For grid-connected storage, only the capacity price is provided. Labor costs are not charged.

What the draft proposes for network charges for battery storage systems:

• Only capacity price, no labor price: Grid-connected storage pays an annual network fee based on its contractually agreed network connection capacity. The capacity price corresponds to the amount of the feed-in fee for generation facilities.
• No double burden: Consumption-dependent labor costs for quantities of electricity that a storage facility consumes and re-injects should not be charged, as long as the quantities can be measured and quantified.
• Dynamic network charges later: Dynamic remuneration components are not to be included in the calculation before January 1, 2030, and no later than January 1, 2033. The details are governed by a separate determination.
• Local storage: Storage in prosumer systems in the low voltage range does not incur a separate storage fee.

An overview of the entire draft regulation can be found in our article. AgNes Draft Determination 2026: The Network Fee Reform from 2029 at a Glance.

Who retains the exemption? Three groups, three results

According to the design, storage can be divided into three groups:

What is important is the difference compared to the current legal situation: According to the draft, a timely commissioning alone is no longer sufficient. If the FID is not in place by the deadline, storage facilities are to pay the new network charges based on capacity price from January 1, 2029, even if they come online before August 4, 2029.

When is the FID considered to have been met?

According to the draft, two conditions must be met:

1. Binding orders: The future operator has ordered plant components obligatorily, namely at least half of the investment volume. Plans, non-binding negotiations, and reservations are not sufficient.
2. No solution from the contract without significant financial damage: The operator may not be able to terminate the order contracts without incurring significant financial losses, for example due to agreed contractual penalties.

Compared to the May status quo, the measure has been clarified: instead of „approximately half“, the draft requires at least half of the investment volume.[8] The previously announced binding commitment to grid connection is no longer included in the draft.[4] The draft does not specify which documents are sufficient as proof. It requires proof „in an appropriate manner“.

We explain the details of the FID mechanism, open interpretation questions, and documentation in the article. FID for battery storage: The AgNes deadline for net charging fee exemption. You can find an overview of all the dates in AgNes Deadlines 2027/2029: What applies to battery storage systems now.

The deadlines at a glance

Industry calls for a later cut-off date

The industry associations consider the deadline too tight. The BVES demands that trust protection be linked solely to commissioning within the legal deadline, alternatively a later deadline in 2027. The BEE would also like to recognize order contracts with a deferred condition for battery storage systems and considers a lower order threshold of 20 % for large projects to be appropriate. These are demands that have not yet been accepted by the BNetzA. Planning is only possible with the deadline in the draft.

What are the network charges for new battery storage systems?

For storage without retention period, the network charge is calculated according to a simple logic:

Network fee per year = contractually agreed network connection capacity (kW) × capacity price (€/kW and year)

The capacity price corresponds to the feed-in fee for generation facilities. It is to be calculated as a rolling five-year value. 50 % of the nationwide regulated energy and loss energy costs of the transmission network operators are included, as well as a base amount of €0.50/MWh. The BNetzA assumes a range of approximately 4 to 7 € per kW and year Out of the question. This is a matter of magnitude, not a forecast: The capacity price for 2029 is not yet fixed. Should this remain unchanged, annual grid fees for a battery storage system with a capacity of 10 MW and an equally large network connection capacity would amount to €40,000 at best and €70,000 at worst.

Two points are important for the calculation:

• The network charge is linked to the capacity, not to the usage. A storage device that loads and discharges repeatedly several times a day does not cost more than a storage device with few cycles at the same connection capacity.
• The network charge for storage is not capped. The BEE criticizes the poor predictability of forecasts and advocates a cap of €4.5 per kW per year and a price fixing when submitting the permit documents.

Network charges depending on the deployment scenario

How a storage system is billed depends on how it is connected to the grid. The draft distinguishes between grid-connected and off-grid storage systems.

The variety of possible configurations is demonstrated by an example from the BEE: Two technically identical 50 MW storage systems could be charged with around €283,000 annually in 2029, or be completely free of charge depending on whether the storage system is connected to a protected existing facility and the existing capacity is not expanded. The association sees this as a disadvantage for standalone projects compared to operators with generation capacity.

For a more detailed explanation of the mixed concepts, please also read our articles on:

• Standalone Storage
• Co-Location-BESS
• Green electricity storage
• Grey Water Storage Tank

What project developers and operators should now examine

1. Document FID criteria. Binding orders exceeding at least 50 % of the investment volume and the contractual commitment must be submitted before January 1, 2027, and must be verifiable to the network operator by March 31, 2027.
2. Plan the commissioning backwards. August 4, 2029 applies in addition to the FID and the proof of compliance requirement. Contracts, orders, network connection approval, delivery times, and the construction phase should be consistent with this.
3. Consciously dimension the connection capacity. Since the network charge is linked to the contracted capacity, overbuilding and congestion effects are reduced. Flexible Connection Agreements (FCAs) Directly to the cost side. Whether FCA only charges for the secured capacity is a matter for the industry to decide, but it has not yet been regulated.
4. Calculate network charges based on capacity pricing as a scenario. Anyone planning without a standing guarantee should include a range of €4 to €7 per kW and year in the economic calculation.
5. Clarify the measurement and reporting concept. Section 118(6) of the EnWG refers to Section 21 of the EnFG for the proportional exemption. The measurement concept, quantity limits, and reporting deadlines should be coordinated with the network operator and the marketer.
6. Consider construction cost subsidies separately. They are treated outside of AgNes in a separate procedure. The draft does not yet specify any requirements for this.
7. Monitor the decision. Until the final decision is made, the BNetzA can still change the draft, even on the FID date.

CUBE CONCEPTS designs, finances, and operates battery storage systems and early on examines with customers whether a project meets the requirements for asset protection.

FAQ: Grid fees for battery storage systems

Sources and Legal Basis

1. § 118, paragraph 6 of the EnWG – Transitional provisions, exemption from network charges for electricity storage systems.
2. Federal Network Agency – Press release of May 27, 2026: Preliminary status of the reform of the electricity network fee system (AgNes).
3. Federal Network Agency – Briefing „Preliminary opinion in the AgNes designation process“, May 27, 2026.
4. RAUE Rechtsanwälte – „AgNes: BNetzA publishes full draft regulation on the new network tariff system for electricity“ (Draft regulation dated August 6, 2026).
5. Battery storage report – „AgNes Draft Regulation 2026: BNetzA sets the FID deadline for storage to January 1, 2027“, as of October 3, 2026 (analysis of the draft including BVES position).
6. Federal Association for Renewable Energy (BEE) – Opinion on the AgNes regulation draft, September 18, 2026.
7. pv magazine – „Consultation on final AgNes regulation draft opens“, August 6, 2026.
8. CMS Deutschland – „AgNes-Draft of the BNetzA: What should change for producers, storage facilities and electrolysers regarding network charges“.
9. RAUE Rechtsanwälte – „EnWG-Novelle: Erweiterung der Netzentgeltbefreiung für Speicher und bidirektionale Ladepunkte“ (teilweise Befreiung bei Mischbetrieb).
10. By Bredow Valentin Herz – „Net-metering exemption for stand-alone storage: System failure due to new regulation and a need for action in practice?“ (Reference to § 21 of the EnFG, measurement and reporting obligations).

Status of research: October 26, 2026. The AgNes procedure is not complete. The content presented is based on the draft regulation of August 6, 2026 and may change until a decision is made. This article does not replace legal advice.