Battery storage — §19 Paragraph 2 Sentence 1 of the StromNEV

Atypical Grid Usage — the medium-voltage mechanism expiring on 12/31/2028

For industrial companies in the medium or high voltage range with an atypical load profile during peak load periods, §19 para. 2 sentence 1 StromNEV reduces the individual grid fee. In a practical example: 1 MW peak reduction through BESS, €120,000 less in the power component per year, €480,000 cumulatively over four billing years. Application deadline with the distribution system operator: September 30, 2028.

30.09.2028

Application deadline at the VNB
last submission opportunity

31.12.2028

Exemption §19 Paragraph 2 Sentence 1
after Agnes from 01/01/2029

120 €/kW

Typical performance price
Medium-voltage Industry

€480000

Cumulative savings in the practical example
over four billing years

regulates §19 Paragraph 2 Sentence 1 of the Electricity Grid Neighborhood Ordinance

Atypical Grid Usage — Definition

A consumer's load profile that clearly deviates from the general grid load profile within the peak load periods (HLZ) published by the distribution system operator. Those who draw significantly less power during HLZ than the annual average are considered atypical.

The Electricity Grid Fee Ordinance distinguishes between typical and atypical grid usage. Typical usage is a load profile that follows the general grid load profile – meaning it draws electricity at the same time as the majority of consumers. Section 19(2), sentence 1 of the StromNEV allows atypical users an individualized grid fee: the basis for calculation is not the annual peak load, but the peak load within the peak load time windows – and this can be specifically reduced through operational control or a battery storage system. The difference between the annual peak load and the peak load during peak load time windows, multiplied by the demand charge, results in the savings.

Prerequisites from the regulatory text: Medium or high voltage connection, full utilization hours at least 7,000 per year or at least 100 hours of HVAC difference on average per year, load profile report as an application attachment, determination by the distribution system operator.

In the glossary: High load time window · Full utilization hours.

Mechanism — High Load Time Window and Targeted Load Shifting

Each distribution network operator publishes the peak load windows for its network area annually. Typically, there is a summer window and a winter window, each on weekdays on several days per week, often in the evening hours. Outside these windows, load consumption is not critical for the calculation of network charges.

Those who place their peak load in the central load center pay in full. Those who shift their peak load out of the central load center pay the individual grid charge—calculated based on the reduced central load center peak, not on the undiminished annual maximum load.

A battery storage system automates this load shifting. Every half hour, the energy management system detects the entry into a peak load time window and discharges the storage system precisely to cover critical peak loads. Outside of peak load times, the storage system is controllably recharged – preferably during low tariff periods or with self-generated solar power.

Medium-voltage BESS park: Container facility designed for load shifting during peak demand periods.

Burden of proof and load flow analysis

Atypical grid usage must be proven by a load profile study. The basis is the half-hourly load profile over twelve months, which is usually available from the distribution system operator via the connected smart meter gateway or RLM measurement. The load profile deviation is shown quantitatively: percentage peak load reduction, difference power in kW, full load hours above and below the threshold.

If a storage system is used for load shifting, the planned BESS behavior is part of the application scope. The distribution system operator may accept a future-oriented expert opinion, provided that the technical design of the storage system – power, energy, control logic – is documented.

Prerequisites — who is eligible for the individual grid usage fee

§19(2) sentence 1 of the StromNEV is directed at industrial companies with clearly deviating load profiles. The ordinance quantifies the requirements as follows:

Voltage level Medium voltage or high voltage. Low-voltage connections do not fall under Section 19 (2) Sentence 1 of the German Electricity Grid Access Ordinance (StromNEV).
Full Utilization Hours OR HLU Difference At least 7,000 full operating hours per year or at least 100 hours of load difference between the annual peak load and the HLZ peak load.
Atypical load profile Measurably deviating from the network load profile in the high-load time windows published by the VNB.
Final load assessment Mandatory application attachment with half-hourly load profile evaluation over twelve months.
Assessment notice The claim only arises through the grid operator's decision—it's not automatic.

In practice, §19 atypical users are mostly industrial companies with continuous shift production or with easily predictable load downtimes. Two-shift operations without weekend loads and three-shift operations with shift change breaks are typical scenarios. Companies with large heat accumulators or thermal buffer processes can also often be shifted to peak load hours.

Use Case — Medium Voltage Industrial Site with 1 MW BESS

An industrial medium-voltage site with an annual peak load of 4,000 kW is installing a battery storage system with a capacity of 1 MW and 2 MWh for targeted peak load shifting. The load profile is reshaped so that the peak load within the peak load time windows is reduced to 3,000 kW. Outside of the peak load times, the load profile remains unchanged.

Position	Before optimization	After optimization
Annual Peak Load (HLZ Peak)	4.000 kW	3.000 kW
Performance Price (typical medium voltage)	120 €/kW/year	120 €/kW/year
Performance component grid charge	€480,000/year	€360,000/year
Savings per year	—	120,000 €
BESS for load shifting	—	1 MW / 2 MWh
Over four billing years (IBN 2025/2026 to expiry 12/31/2028)	—	€480,000 accumulated

Assumptions

Commissioning of storage between 2025 and 2026, four full billing years until the expiry of §19 on 12/31/2028. Capacity price of €120/kW/year is a typical medium-voltage value; actual capacity prices vary depending on the distribution network operator between around €60 and over €180/kW/year. Load profile without special effects (no large consumer seasonal effect, no self-generation anomalies).

Source: CUBE CONCEPTS Project Experience. Actual savings depend on the grid operator's power price, load profile, and voltage level.

Application path - four steps at the distribution system operator

The application procedure according to §19 para. 2 sentence 1 StromNEV is managed by the distribution system operator and follows a recurring structure. Those who submit their application completely by September 30, 2028, can claim the individual grid fee in the following billing year.

Half-hourly load profile over twelve months

Request the RLM load profile or smart meter load profile from the distribution system operator. Data format is usually CSV with 17,520 or 17,568 half-hourly values per year.

Duration: 2–4 weeks delivery time at the network operator

HLZ Identification and Load Profile Analysis

View the distribution network operator's HLZ publication. Segment the load profile into HLZ and non-HLZ hours. Quantify the difference between the annual peak load and the HLZ peak load.

Duration: 1–2 weeks analytical evaluation

Submit the application with the load profile report to the network operator.

Load flow report as part of the application. If load shifting through storage is planned: document the technical design of the BESS. The deadline of 30.09.2028 refers to the last permissible application submission within the validity period.

Expert report preparation time: 4–6 weeks

Wait for the assessment notice

The distribution network operator checks the application facilities and issues a determination notice for the individual grid fee. In the event of significant changes to the load profile, an annual confirmation is required.

Processing time: 6–12 weeks

First 09/30/2028 — Application deadline and investment logic

The application deadline with the distribution system operator ends on September 30, 2028. Anyone who has not submitted a complete application by then can no longer claim §19 para. 2 sentence 1 StromNEV — not even for the remaining part of the year 2028. The regulation in its current form expires on December 31, 2028; AgNes will apply from January 1, 2029.

This creates a hard investment edge: The sooner the storage goes online, the more full billing years will be available under the §19 regime.

Storage commissioning	Full §19 billing years possible	Max. cumulative savings in the practical example
2025	4 (2025, 2026, 2027, 2028)	480,000 €
2026	3 (2026, 2027, 2028)	360,000 €
2027	2 (2027, 2028)	240,000 €
2028	1 (pro rata)	Less than or equal to 120,000 EUR

The planning and realization lead time for an industrial BESS typically ranges from six to twelve months, depending on grid connection, permits, and delivery times. Those who want to benefit from a full three accounting periods in 2026 should start plant planning no later than mid-2025.

What comes after December 31, 2028 — Transition to AgNes

Effective January 1, 2029, AgNes (the balancing mechanism for grid-supporting control) will replace the previous system of individual grid fees under Section 19(2), sentence 1 of the StromNEV. The legal basis is the BNetzA regulation GBK-25-01-1#3, the discussion paper for which was published on September 24, 2025; the final regulation is expected by the end of 2026.

AgNes is not a direct successor in the sense of a one-to-one translation. Instead of a fixed tariff, a mechanism with two operating modes is created: a grid-led control, where the storage system supplies power when the grid needs it, and a price-led marketing, which reacts to spot market signals. Both modes can be operated with the same BESS system – the operator makes the choice.

For industrial companies, this means that a storage facility that has been shifted under §19 atypical peak loads until 2028 can be transferred to the AgNes mechanism from 2029 onwards without hardware changes. The switch takes place via energy management and the marketing interface.

A complete overview of the grid fee mechanisms — §118 EnWG, §19 StromNEV and AgNes — and their combination possibilities can be found at Network Fee Optimization Overview Page.

AgNes from 01.01.2029: BESS plants become actors in grid-serving control and market-driven marketing.

Scope of application check — which legal norms apply to industrial companies?

Before making an investment decision, it is worthwhile to soberly assess which legal bases are actually relevant for industrial applications and which are not. With reference to Section 19, Paragraph 2, Sentence 1 of the StromNEV, the following picture emerges:

Legal norm	Area of application	Industry
§19 Paragraph 2 Sentence 1 of the StromNEV	Atypical grid usage - individual grid fee for medium/high voltage connection with deviating load profile. Application deadline 09/30/2028, expiry 12/31/2028.	✅
§118 para. 6 EnWG	Network charge exemption for electricity storage for 20 years from commissioning. Commissioning deadline August 4, 2029. Detailed information on the network charge optimization overview page.	✅
§11c EnWG	Grid connection rules for storage and generation facilities — applicable to all industrial BESS projects.	✅
§35 BauGB	Outdoor privilege for BESS outdoors as of 01/01/2026 — relevant for site selection, not for grid fee mechanism.	✅
§42c EnWG	Energy sharing regulation for end customers in private energy communities. Not intended for industrial companies.	❌
§14a EnWG	Low-voltage end-customer regulation for controllable loads. Not applicable to medium or high-voltage industrial connections.	❌

For industrial use cases in medium/high voltage, §19, §118, §11c, and §35 are the operationally relevant standards. §42c EnWG and the Low Voltage End Consumer Regulations are regulatorily clearly formulated as end consumer instruments; their application to medium/high voltage industrial operations is not intended.

CUBE Models for Implementation

Industrial companies can implement the §19 atypical mechanism through two models—with or without equity investment. Both models are independent of the regulatory mechanism; same storage, same load shifting effect, different balance sheet impact.

BESS Contracting

Go to BESS-Contracting →

BESS purchase

Go to BESS purchase →

Economic models are based on public market benchmarks. Specific calculations for your site are prepared in the load profile meeting.

Frequently asked questions

What does Section 19, Paragraph 2, Sentence 1 of the StromNEV regulate?

The standard allows consumers connected to medium or high voltage with atypical load profiles an individual grid fee. The basis of calculation is not the annual peak load, but the peak load within the peak load time windows published by the distribution system operator. Those who specifically reduce their peak load time window peaks will pay less for the capacity component accordingly.

Who can make use of §19 (2) Sentence 1 of the StromNEV, and who cannot?

Industrial companies with medium or high voltage connections, at least 7,000 full utilization hours per year or at least 100 hours of HLZ difference, and demonstrably atypical load profile. Low-voltage end customers, households, and energy communities are excluded — other regulations are provided for these target groups.

How is the peak load window determined?

Each distribution network operator publishes its peak load times annually on its website or in its tariff sheet. Common are a summer and a winter peak load time, each on weekdays on several days a week, often in the evening hours. The windows vary regionally and can shift from year to year.

How much grid fee savings are realistic?

The scale results from the capacity price multiplied by the difference between the annual peak load and the reduced peak load utilization hours. In the practical example with a 1 MW peak reduction and a capacity price of €120/kW/year, €120,000 per year is realistic. The range of typical medium-voltage capacity prices is roughly from €60 to over €180/kW/year – the individual savings should be scaled accordingly.

Which sections of the EnWG are relevant for industrial companies, and which are not?

For industrial purposes, the following are relevant: §11c EnWG (Grid Connection Rules), §118 Paragraph 6 EnWG (Storage Grid Fee Exemption), and §35 BauGB (Outdoor Privilege). The following are not intended for industrial purposes: §42c EnWG (Energy Sharing for End Customers) and low-voltage end customer regulations for controllable loads. Anyone planning with the wrong regulation is building on an area of application that does not cover the constellation at all.

How long is §19 Section 2 Sentence 1 of the StromNEV still valid - and what comes after?

The mechanism will expire in its current form on December 31, 2028. The deadline for submitting applications to the distribution system operator is September 30, 2028. Starting January 1, 2029, AgNes (BNetzA Decision GBK-25-01-1#3) will take effect with a grid-driven and a price-driven application mode. Storage systems that were operated under Section 19 until 2028 can be transferred to the AgNes mechanism without any hardware changes.

Is §19 still worthwhile with commissioning in 2026?

Yes: With IBN 2026, three full billing years under the §19 regime are possible (2026, 2027, 2028). In the practical example with an annual saving of €120,000, this is a cumulative €360,000. With IBN 2025, it would be €480,000 over four billing years. The investment logic is driven by the hard cutoff date - the later the IBN, the fewer application years.

How large does the BESS need to be dimensioned for §19 atypicality?

Rule of thumb: For every 1 MW of desired peak reduction, a BESS with approximately 1 MW of power should be dimensioned. The energy capacity is determined by the duration and frequency of peak load hours—2 to 4 MWh are typical for a 4-hour winter peak load on weekdays. The exact dimensioning is carried out through a half-hourly load profile analysis. Those who intend to use other applications in parallel, such as grid services or self-consumption, should consider the stack approach on the multi-use side.

Sources and Legal Basis

StromNEV § 19 Paragraph 2 Sentence 1 — Grid Charge Ordinance, current version with expiration date December 31, 2028. Full text at gesetze-im-internet.de
BNetzA Decision GBK-25-01-1#3 — Agnes Mechanism as of January 1, 2029, Discussion Paper from September 24, 2025, final determination expected end of 2026. Federal Network Agency
BMWE Publications on Grid Fee Reform Consultation roadmap for AgNes introduction and CISAF aid framework for industrial energy projects.
CUBE CONCEPTS Model Calculation — Practical example is based on a real medium voltage grid configuration, anonymized as „industrial medium voltage location”. Calculation basis: half-hour load flow, medium voltage power price 120 €/kW/year.

Status & notes

Content as of: May 6, 2026. The regulatory situation regarding §19(2) sentence 1 StromNEV (expiring December 31, 2028) and the AgNes regulation (entering into force January 1, 2029) is continuously evolving. Contents will be updated in the event of significant changes.

Model calculations: All figures are model calculations based on public market benchmarks. Actual economics depend on the load profile, voltage level, demand charge and the specific system design.

This is not legal or tax advice: The content does not replace individual legal, tax, or subsidy advice. For applications to the distribution system operator, we recommend project-specific support from qualified bodies.

Realized Projects with Industrial Companies

CUBE CONCEPTS develops and implements energy projects across Europe. A selection of the industrial partners:

TI Automotive

Magna

Valeo

voestalpine

Tenneco

ITW

View all references with key figures per project →

The §19 application deadline remains on September 30, 2028. 23 months.

Back-end analysis in 30 minutes. Half-hourly HLZ identification. Model calculation of maximum achievable savings in various IBN scenarios.