News on the grid access charge reform: Guidelines from the BNetzA dated January 16, 2026

What the Federal Network Agency's points of orientation from January 16, 2026, mean for practice

Multi-use storage systems that are used for both self-consumption optimization and for arbitrage, balancing energy, or grid-supportive applications are considered a central flexibility option for the energy transition. At the same time, they move within a regulatory tension between network financing, market integration, and consumer protection.

With the points of orientation for storage network charges from January 16, 2026, the Federal Network Agency (BNetzA) has for the first time concretized how this tension field should be resolved in the future. Although many detailed questions remain open, clear guidelines can be derived from the document that are already relevant today for installers, project developers, storage manufacturers, wholesalers, municipal utilities, and EMS providers.

1. Introduction and status quo: new rules, open implementation

The starting point of the current discussion is the amendment of § 118 para. 6 of the Energy Industry Act (EnWG) in December 2025. This amendment extends the exemption from network charges for electricity storage to so-called mixed current or multi-use storage. This now also includes storage systems where only part of the stored energy is fed back into the grid, while another part is consumed behind the connection point.

The goal of this legislative amendment is clear:

Arbitrage and market-oriented use of storage should not be devalued by network charges.

At the same time, the practical implementation is still unclear. In particular, a binding answer is missing on how to differentiate between market movements due to storage and consumption-related use in practice. This is exactly where the planned MiSpeL (Measuring and Storage Logic of the BNetzA) comes into play (more on this here). It aims to specify how storage electricity is measured and accounted for.

In parallel, the fundamental reform of network charges is taking place with AgNes (General Network Charge System for Electricity) after the expiry of the Electricity NEV. The points of orientation are part of this AgNes process and mark the current state of regulatory considerations – still without binding specifications, but with a clear direction.

2. Key statements of the points of orientation from January 16, 2026

The Federal Network Agency makes several fundamental decisions clear in its paper:

• A permanent exemption from network charges for storage is not legally and economically tenable.

• Storage should in the future generally contribute to the financing of networks.

• At the same time, storage should not be penalized for grid-supportive behavior, but specifically rewarded.

• Multi-use storage plays a special role as they fulfill both consumption-like and market-oriented functions.

To connect these goals, the BNetzA for the first time systematically distinguishes between network charges with a financing function and network charges with an incentive function.

3. Network charges with a financing function: paying for real network use

The network charges with a financing function serve exclusively to cover network costs. In the future, they are to consist of two elements.

Capacity component:

Instead of the technical connection capacity, a contracted capacity chosen by the network user is decisive. It determines a fixed cost share and is meant to finance the long-term provision of network capacity.

Work prices (AP1 / AP2):

As long as electricity consumption remains within the contracted capacity, a low work price (AP1) applies. If the capacity is exceeded, a higher work price (AP2) comes into effect, which sets incentives for realistic capacity selection.

4. Network charges with an incentive function: purposefully rewarding flexibility

In addition to the financing function, the BNetzA plans to introduce dynamically priced network charges with an incentive function. These do not serve financing, but the targeted steering of network usage behavior.

Characteristic features are:

• a time- and location-dependent design,

• a symmetrical application to consumption and feeding in,

• and a rate-sensitive effect.

Grid-relieving behavior – such as charging during network overload or feeding in during bottlenecks – can lead to credits. Network-burdening behavior may incur additional costs. Storage systems thus gain the opportunity for the first time to achieve direct revenues through grid-supportive operation via the network charge regime. The decision-making chamber aims for an introduction of network charges with an incentive function starting in 2029 for the transmission grid and the high-voltage level.

5. Interaction with § 118 para. 6 EnWG and MiSpeL in multi-use storage

For multi-use storage, the interaction of the regulatory frameworks is crucial. The legal exemption under § 118 para. 6 EnWG protects market movements related to storage, particularly arbitrage. However, it does not protect the end consumer.

Specifically, this means:

• Electricity flows Grid → Storage → Grid should be exempt from network charges with a financing function.

• Electricity flows Grid → Storage → Consumer are considered normal consumption and remain chargeable.

For this differentiation to function in practice, MiSpeL is central (more info in the article here). Only when it is clearly defined and measured what amounts of electricity are stored, fed back, or consumed can § 118 para. 6, balancing, and the new network charges be implemented without contradictions.

6. Two examples – compactly explained

To illustrate, let us consider a multi-use storage system at a commercial connection point, which can load electricity from the grid, feed electricity into the grid, and also use electricity in its own operation.

Basic assumptions (same for both examples)

For the network charges with a financing function, the following assumptions apply:

• Contracted capacity: 1 MW

• Work price within the contracted capacity (AP1): 20 €/MWh

• Capacity price: 10 €/MW per hour

• Analysis period: 4 hours

The capacity price is thus calculated as:

1 MW × 10 € × 4 h = 40 €

For the network charges with an incentive function, the following (simplified) dynamic prices are assumed:

• Electricity consumption in a surplus hour: −80 €/MWh

• Electricity consumption in a bottleneck hour: +100 €/MWh

• Electricity feeding in during a bottleneck hour: −50 €/MWh

Operations of the storage system and the business

The storage system and the business behave the same in both examples:

• At night, the storage system loads 1.0 MWh from the grid.

• In the morning, the storage system discharges 1.0 MWh:

  
  

  • 0.6 MWh are fed into the grid,

  • 0.4 MWh are consumed in the operation.

  
  

  
  

• Additionally, the operation directly consumes 1.5 MWh from the grid at noon.

• The storage losses amount to 0.1 MWh.

The only difference between the two examples is the network situation during the midday electricity consumption.

Example 1: The midday electricity consumption is net-neutral

In this case, the additional grid consumption of 1.5 MWh occurs in an hour without network bottlenecks.

Financing function

For the financing function, only those amounts of electricity are considered that are not fed back into the grid:

• Self-consumption from storage: 0.4 MWh

• Storage losses: 0.1 MWh

  → chargeable amount: 0.5 MWh

Calculation:

• Work price storage: 0.5 MWh × 20 €/MWh = 10 €

• Capacity price: 40 €

• Work price operation: 1.5 MWh × 20 €/MWh = 30 €

Total financing function: 80 €

Incentive function

• Charging in surplus hour: 1.0 MWh × (−80 €/MWh) = −80 €

• Feeding in during bottleneck hour: 0.6 MWh × (−50 €/MWh) = −30 €

Total incentive function: −110 €

Total result of Example 1

80 € − 110 € = −30 €

The location achieves a net revenue of 30 € in this case.

Example 2: The midday electricity consumption falls into a bottleneck hour

In this second case, only one thing changes:

The additional grid consumption of 1.5 MWh now occurs in a bottleneck hour.

Financing function

Unchanged compared to Example 1:

• 80 €

Incentive function

• Charging in surplus hour: −80 €

• Feeding in during bottleneck hour: −30 €

• Electricity consumption in bottleneck hour: 1.5 MWh × +100 €/MWh = +150 €

Total incentive function: +40 €

Total result of Example 2

80 € + 40 € = 120 €

The location pays 120 € additional network charges in this case.

Short comparison of the two examples

With identical storage, identical operations, and identical consumption, the results differ solely based on the network situation at the time of electricity consumption:

• Example 1: −30 €

• Example 2: +120 €

The difference arises solely from the dynamically priced network charges with an incentive function, not from the size of the storage or the installed technology.

7. Open questions and challenges

Despite clear guidelines, central questions remain open. Project developers and manufacturers must clarify how bankable business models with dynamic and potentially volatile network charges are. Municipal utilities and network operators face the challenge of integrating new incentive charges with existing instruments such as individual network charges under § 19 Electricity NEV. EMS providers need to technically and economically link market and network signals.

Additionally, questions of IT implementation, data transparency, abuse prevention, and European law non-discrimination arise. The biggest challenge lies less in the technology than in the coherent integration of the regulatory frameworks.

Conclusion

The points of orientation from the Federal Network Agency mark a fundamental paradigm shift. Storage will no longer be privileged in a blanket manner but treated differentially. At the same time, flexibility is systematically integrated into the network charge system for the first time and potentially compensated. For multi-use storage, new opportunities arise – provided that measurement concepts, operating strategies, and business models are adapted early to the new logic.