Brief overview
- Ü20 installations are photovoltaic installations whose 20-year EEG support period has expired under § 25 of the EEG – 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, commercial installations over 100 kWp that are not connected to the grid are not entitled to automatic connection compensation from the network operator: they are required to switch to other direct marketing (Section 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 U20 regulations, but is relevant for the repowering decision: New installations from January 1, 2027 fall under a new support scheme with tenders 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, successively the first generations of the large EEG-2000/2004 expansion wave have been affected. For commercial operators, this is no minor issue: Solar and ground-mounted systems from the early 2000s that are now scheduled to be excluded from the support scheme often fall exactly into the same installation size class (>100 kWp) for which an automatic connection subsidy does not apply.
What are the legal implications when EEG subsidies expire?
The elimination of subsidies does not mean the end of plant operation – the plant may continue to produce, only the marketing of the generated electricity changes.
Systems over 20 years old up to 100 kWp
For them, the legislator created a temporary connection regime with the Solarpaket I, which has now been extended until 31.12.2032. The network operator automatically remunerates the electricity supplied with the annual market value of solar minus marketing costs, capped at a maximum of 10 ct/kWh (§ 23b EEG). In 2025, the net value was, for example, around 3.8 to 4.3 ct/kWh. A separate agreement is not necessary for this. The 2032 deadline itself is systematically re-framed in the draft government bill for the EEG 2027 and will henceforth be enshrined in § 25 paragraph 3 of the EEG 2027, instead of remaining as it has until now in the transitional provisions – in terms of content, nothing will change.
Over-20 systems exceeding 100 kWp
For these – and thus for the majority of the production facilities relevant to industry – the connection fee does not automatically apply. They are dependent on the other direct marketing methods under § 21a of the EEG Act. In this case, a direct marketer sells the electricity on the stock exchange, without any EEG subsidy entitlement or market premium being applicable. Proof of origin can also be marketed separately.
Certain technical obligations remain in place, however: For systems between 25 and 100 kWp in voluntary direct marketing, the obligation to be remotely controllable under § 10b EEG 2023 remains in effect. The draft government bill for EEG 2027 tightens this requirement for newly installed systems marketed directly: The previous 25 kW threshold is eliminated, meaning that all newly installed systems marketed directly must be technically remotely controllable regardless of their output (Section 10b Paragraph 1 EEG 2027). For existing Ü20 systems that are considered existing installations, this change to the previous requirement does not change anything. The connection to the grid itself remains unchanged.
A Comparison of Options for PV Systems Over 20 kW
| Continued operation ≤100 kWp | Continued operation >100 kWp | Increase in self-consumption (BESS) | PV Expansion | PV Repowering | |
| Brief Description | Automatic Connection Fee (Utility Company) | Requirement for Direct Marketing | Maximize self-consumption, feed surplus power into the grid | Additional modules (mixed operation) | Complete replacement, new 20-year subsidy |
| Legal basis | § 23b EEG 2023 (until Dec 31, 2032) | §21a EEG (Obligation to Sell Directly) | Section 23b of the EEG + Section 19 of the EEG (Self-Consumption) | §23b EEG + new EEG remuneration | New EEG remuneration (§ 21 EEG) |
| Compensation/Revenue | ~4.3–4.4 ct/kWh (2026, net) | Market value solar + market premium (minus direct marketing fee) | saved commercial procurement costs | Old: ~4.3 ct/kWh; New: 6.2 ct/kWh (20 years) | New: 6.2 ct/kWh (20 years) |
| distribution channel | Automatically via network operator | Mandatory: Contract with direct marketer | Automatic (surplus) or PP optional | mixed compensation (old + new) | New contract with grid operator |
| One-time costs (in case of self-financing) | €0 | 0 € (DV contract free of charge) | New meter concept, storage system & possibly EMS | PV installation costs | PV repowering costs mostly include inverter |
| Ongoing costs | Marketing flat rate | IT fee + marketing flat rate | Low (maintenance + operation) | Low (maintenance + operation) | Low (maintenance + operation) |
| Deadline for the EEG 2027 | No deadline (secured until 2032) | No deadline (secured until 2032) | Grid fee exemption for energy storage systems at INB until August 4, 2028 | Auction award until 12/31/2026 for EEG 2023 remuneration | Auction award until 12/31/2026 for EEG 2023 remuneration |
| Profitability | Low (only sensible with very low self-consumption) | Low to medium (DV fee reduces revenue) | High (saved procurement costs > feed-in tariff) | Medium to high (depending on self-consumption + expansion) | Medium to high (depending on self-consumption + expansion) |
| CO₂ savings | Still high (full feed-in) | Still high (full feed-in) | Very high (self-consumption + feed-in) | Higher (higher yield) | Very high (new, more efficient modules) |
| Flexibility | Low (no optimization) | Middle | High (controllable self-consumption) | Medium (mixed compensation) | High (new technology, storage if applicable) |
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 U20 installations, the government draft amendment to the EEG 2027 will not change anything initially – the described regulations regarding connection remuneration (§ 23b, § 25 paragraph 3 EEG 2027) and other direct marketing (§ 21a EEG) will continue unchanged, as these are existing installations. However, the reform will become relevant when a repowering is considered. A newly constructed installation will automatically be subject to the support scheme planned from January 1, 2027, no longer the classic fixed feed-in remuneration.
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 installations, the new refinancing contribution (§ 21d EEG 2027) is particularly relevant for repowering: the government draft stipulates that from 100 kW installed power, all subsidized installations will in future pay revenue above the applicable value via a two-way difference contract (CfD) in high-price phases – in addition to the existing sliding market premium, not as a replacement for it. We have described this mechanism in detail in our contribution to the EEG 2027 & Network Package: Cabinet Decision on the Refinancing Contribution (CfD) in summary.
Deadlines for over-20-year PV systems during expansion and repowering
For repowering or expansion decisions, this results in time-based levers. Those who receive an auction surcharge for a planned repowering or expanded U20 facility before January 1, 2027 will still secure the known conditions of the current EEG 2023 without a refinancing contribution. Those who receive the surcharge thereafter should plan from the outset with a revenue deduction pursuant to § 21d of the EEG 2027 and the new funding logic. Since it is still a government draft at the time of publication of this report, which requires the approval of the Bundestag, the Federal Council, and the European Commission, this timing consideration should be communicated with reservations until final adoption.
Recommendations for operators of commercial post-20-year (Ü20) systems
- 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.
- 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.
- Evaluate technical condition: Inverter remaining service life, cabling, and module performance determine whether continued operation or repowering is the more sensible option.
- Examining storage retrofits as a leverage for maintaining value: A retrofitted battery storage system increases the share of self-consumption and creates additional revenue sources (e.g., redispatching, demand response) – especially as feed-in tariffs disappear, self-consumption optimization becomes increasingly important.
- 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.
- 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
What happens automatically when the EEG funding for my commercial PV system expires?
For systems over 100 kWp, nothing happens automatically – without an active re-registration to other direct marketing, there is a risk of a revenue gap, since the grid operator's feed-in tariff only applies to systems up to 100 kWp.
Do I have to shut down my over-20-year-old system?
No. There is no obligation to decommission. The plant can continue to be operated indefinitely as long as it functions properly from a technical and safety perspective.
Do I get a 20-year subsidy again with repowering?
Basically yes, the 20-year period pursuant to Section 25 of the EEG remains in place even in the government draft for the 2027 EEG. For installations of 100 kW and above, the draft also adds the refinancing contribution pursuant to Section 21d of the 2027 EEG starting in 2027, which skims off revenues during high-price phases above the value to be applied.
Is a battery storage system worthwhile for a PV system older than 20 years?
Since feed-in after the end of subsidies is remunerated at a significantly lower rate than grid electricity costs, a storage system increases the economically usable self-consumption share and can unlock additional sources of revenue.