At the end of November 2025, the German Federal Ministry for Economic Affairs and Climate Action (BMWK) decided to amend the Power Plant Grid Connection Ordinance (KraftNAV). As a result, large battery storage systems with a capacity of more than 100 MW will no longer be able to connect to the grid under this procedure in the future. The decision currently does not provide for an alternative approval process, leaving it unclear how the grid connection of such large storage facilities will be regulated in the future.
For countless project developers, the question arises of how to implement their storage projects. At the time of the decision, pv magazine Germany reported that the four transmission system operators had more than 500 applications for storage projects with a combined capacity of over 200 gigawatts that had not yet been decided on.
The German Renewable Energy Federation (BEE) criticizes the fact that no new procedure was adopted before the removal from the KraftNAV. As a result, security and planning reliability for projects are no longer possible. “They are taking the second step before the first,” said BEE President Heinen-Esser in a statement from the association. Without a clear framework, there is a risk of long delays and even project cancellations. The 51 GW promised for large-scale storage have thus entered a phase of uncertainty.
In principle, the number of grid connection requests is very high, both for large-scale storage systems and for smaller installations. The current regulation under the KraftNAV, based on the “first come, first served” principle, no longer seems to do justice to the volume and significance of these requests, according to the financial portal onvista.de. According to solarbranche.de, the abolition of the “first-come, first-served” principle – a procedure originally designed for fossil fuel power plants – is intended to bring more structure and regulation to the grid connection process.
Since the Power Plant Grid Connection Ordinance (KraftNAV) was originally designed for conventional large-scale power plants, battery storage systems were initially classified under the same regulatory framework. Accordingly, the KraftNAV regulates grid connection exclusively for generation facilities with a nominal capacity of more than 100 MW to electricity networks with a voltage level of at least 110 kV.
According to established case law of the German Federal Court of Justice, the Federal Network Agency classifies battery storage systems as both consumption and generation facilities. Until then, the scope of application of the KraftNAV extended only to the electricity generation side and left the consumption side unaffected. Against this background, the Federal Ministry for Economic Affairs and Energy (BMWE) implemented a change in direction and removed large-scale energy storage systems from the scope of the KraftNAV, meaning that they are no longer treated as generation facilities within the meaning of this ordinance. The German Renewable Energy Federation (Bundesverband Erneuerbare Energie, BEE) also points out that “battery storage systems are not pure generation facilities and therefore the KraftNAV does not constitute an appropriate procedure for the grid connection process of battery storage systems.”
Objectives and expected benefits of removing large-scale storage from the KraftNAV
Removing large-scale storage systems from the scope of the KraftNAV opens up the possibility of introducing storage-specific regulations in the future, for example, with regard to technical requirements, market roles, or reservation mechanisms. In addition, coordination of scarce grid capacities is expected to improve, according to solarbranche.de. The Ministry for Economic Affairs also stated that “applying the ‘first-come, first-served’ procedure provided for under the KraftNAV to grid connection requests from large-scale battery storage systems would have led to other connection applicants, such as data centers, having virtually no chance of obtaining a grid connection.”
According to the Federal Network Agency and the BMWE, smaller battery storage systems are not affected by this specific change, as they have never fallen within the scope of the KraftNAV. As a result, neither the first-come, first-served procedure nor the deadlines or power-plant-related reservation mechanisms provided for in the KraftNAV apply to these facilities. The grid connection of battery storage systems with a capacity below 100 MW continues to be governed by the general provisions of Section 17 of the German Energy Industry Act (EnWG).
Background: Project realization in the single-digit percentage range
In addition to the goal of simplifying the grid connection process for large BESS through new regulations, it is still unclear whether this will also lead to more commitments for storage projects. Until now, only a very small proportion of connection requests have resulted in completed projects: “The conversion rate is in the low single-digit percentage range. This is mainly because, for a single grid connection point, well over a hundred project developers often submit requests, of which in the end, only one project can be awarded the connection. This competition continues when developers approach multiple marketers, meaning that only a few of the many inquiries ultimately become finalized projects,” says Marc Untheim, Senior Business Development Manager at The Mobility House Energy.
In addition, there was a considerable lack of transparency in the process. According to Untheim, developers often report long periods of positive verbal signals that are not confirmed in writing. “In some cases, shortly before the expected approval, a standardized rejection without justification is issued. Such cases are extremely frustrating for project developers, as they may invest months or even a year in preliminary planning, permitting processes, and financing preparations – only for the project to be discontinued without comprehensible reasons.”
If the expansion of large-scale storage is delayed or blocked, the market ramp-up in the coming years could be slowed. This would affect the supply side, system flexibility, and market mechanisms. Overall, a more suitable procedure is needed that evaluates project applications both qualitatively and quantitatively. “In the long term, a model based on maturity levels would be useful, assessing which projects are already the most developed and are most likely to actually be implemented. That would significantly improve prioritization,” says Untheim.