AgNeS & Large-Scale Storage
AgNeS is meant to reset grid charges for industry and commerce. If you want a discount later, you have to be able to shift load. A large battery can do that. As of 7 October 2026 this is a draft, not a ruling.
What is changing
AgNeS – the Allgemeine Netzentgeltsystematik Strom – replaces the StromNEV regulation. StromNEV and ARegV expire at the end of 31 December 2028; the new system applies from 1 January 2029. The background is a CJEU ruling of 2 September 2021: charge design rests with the regulator, not the rule-maker. The BNetzA conducts the proceeding under case number GBK-25-01-1#3. On 6 August 2026 the Grand Ruling Chamber published the full determination draft for consultation. The consultation closed on 18 September 2026. As of 7 October 2026 the framework ruling has not been adopted; it is still planned for the remainder of 2026. Publication (Bekanntgabe) is envisaged in the draft for 1 January 2027.
For industry and commerce, the rigid baseload privilege under § 19 (2) sentence 2 StromNEV and atypical grid usage under sentence 1 are in principle to be discontinued. The draft provides for transitional rules until 31 December 2031. Thereafter, flexibility-based discounts and the booked-capacity model set the standard: from rigid load to system-friendly behaviour.
Peak shaving with large-scale storage
If you want the discount, you have to steer the load. A battery behind the meter shaves the peaks: it charges when power is cheap and covers the peak from the cell. That lowers the peak the grid charge is based on. Peak shaving is the part you can plan.
A battery can do only one thing in a given time slot. Peak shaving, arbitrage, FCR and aFRR don't run at the same time. The controller picks, each day, the market that pays most right then. When the slot is free, the battery can also earn on FCR, aFRR or the exchange. Under AgNeS it isn't just a cost. It creates the flexibility the discount requires.
Already today: atypical grid usage
You can do this before 2029. Under § 19 (2) sentence 1 StromNEV, end consumers are entitled to an individual, reduced grid charge if their peak-load contribution predictably and significantly deviates from the simultaneous annual peak load – in practice: if their own load peak falls outside the high-load time windows (Hochlastzeitfenster) published by the grid operator. The benchmark is registered load metering (RLM, mandatory from 100,000 kWh per year) in a 15-minute load profile.
Only the highest quarter-hour value within the high-load windows is billing-relevant – and that is exactly the value a large-scale battery lowers. The materiality threshold (Erheblichkeitsschwelle) is set per grid level; the individual grid charge amounts to at least 20 percent of the regular charge. The same storage flexibility that supports atypical grid usage today qualifies for the AgNeS flexibility discounts from 2029.
Who this pays off for
The load profile is decisive. With a flat, steady consumption, peak shaving achieves little; its greatest benefit comes with a volatile load profile featuring pronounced, plannable peaks. As a rule of thumb, deployment becomes economically attractive from an annual consumption of around 500,000 kWh.
Economies of scale add to this: peripheral costs such as foundation, cabling and grid connection are largely independent of battery size – the larger the consumption and the battery, the smaller their share. If the battery can additionally be coupled with on-site PV generation, pure energy costs fall as well.
Grandfathering has a cut-off date
The determination draft no longer confirms the 20-year exemption under § 118 (6) EnWG across the board for every commissioning by 4 August 2029. What matters is a final investment decision (FID) before the planned publication of the ruling (1 January 2027) and commissioning by 4 August 2029. Under the draft, FID is met by binding orders covering at least half of the investment volume that cannot be cancelled without substantial financial loss. A grid-connection commitment is no longer a prerequisite. Anyone who takes the FID only after publication is to pay a capacity charge from 1 January 2029 – even if they still meet the statutory commissioning deadline. Proof of FID to the grid operator is envisaged by 31 March 2027. The benchmark is point 17.5 of the determination draft.
New storage without this grandfathering is to pay an annual capacity charge on the connection capacity, not an energy charge on every kilowatt-hour that passes through. Home storage on the low-voltage grid stays without its own grid charge. Dynamic grid charges for storage are to come in 2030 at the earliest and in 2033 at the latest, with no grandfathering. That is in the draft, not in a ruling. MiSpeL is a different matter, and it is already decided, on 1 October 2026. There is a delineation option and, for PV up to 30 kWp, a flat-rate option. Until 30 September 2027 you need the consent of the grid operator and the metering operator. The flat-rate option also needs EU state-aid approval. MiSpeL applies to the market premium and direct marketing, not the fixed feed-in tariff.
How AgNeS recalculates grid charges
AgNeS replaces today's demand charge with a model of a capacity price (Kapazitätspreis, KP) and a two-tier energy price. The customer books a capacity in kW in advance each year. Within that booking, the low energy price 1 (AP1) applies; any volume above it is billed at the expensive energy price 2 (AP2). In the determination draft of 6 August 2026, AP2 is 200 to 350 percent of AP1.
The smaller the booked capacity, the more consumption falls into the expensive AP2. NAK = grid connection capacity. Schematic, own illustration of the KP/AP model based on the BNetzA AgNeS determination draft of 6 August 2026 (draft values, not adopted).
Why storage becomes the key
Booking a small capacity saves on the capacity price – but risks expensive AP2 at every peak. A large-scale battery resolves the conflict: it shaves the peaks so the site gets by with a small booked capacity and still stays in the low AP1. The capacity is no longer derived retroactively from the annual peak load but chosen in advance.
I walk storage operators and industrial customers through this window: peak shaving first, then FCR, aFRR and EPEX when the time slot is free.
Status: 7 October 2026. The AgNeS determination draft (GBK-25-01-1#3) has not been adopted. The consultation ended on 18 September 2026. A framework ruling is still envisaged for the end of 2026, publication under the draft on 1 January 2027, and practical application from 1 January 2029. Under the draft, the 20-year exemption under § 118 (6) EnWG remains only with FID before that publication (proof by 31 March 2027, point 17.5 of the draft) and commissioning by 4 August 2029. The KP/AP spread (AP2 = 200–350% of AP1) and the storage provisions are draft values. All figures without warranty; the economic assessment requires an individual review of the specific load profile. Not legal advice.
Frequently asked questions
How does a large-scale battery reduce grid charges under AgNeS?
A large-scale battery at the point of consumption uses peak shaving to cut demand peaks drawn from the grid: it charges in low-cost periods and covers the peak load from the cell. Under the planned booked-capacity model this lowers peaks above the booked capacity and keeps the site in the cheaper AP1. The determination draft provides for transitions for baseload and atypical grid usage under § 19 (2) StromNEV until 31 December 2031; thereafter flexibility-based discounts are to set the standard. The controllable large-scale battery delivers exactly the system-friendly behaviour these discounts require.
Will large-scale storage remain exempt from grid charges after 2029?
In the determination draft of 6 August 2026, the 20-year exemption under § 118 (6) EnWG remains only if a final investment decision (FID) was taken before the planned publication of the ruling (1 January 2027) and commissioning takes place by 4 August 2029. Proof of FID to the grid operator is envisaged by 31 March 2027. The benchmark is point 17.5 of the determination draft. Anyone who takes the FID later is to pay a capacity charge from 1 January 2029 – even if commissioned by 4 August 2029. New storage without grandfathering pays a capacity charge, not energy charges on throughput. Home storage in the low-voltage grid remains exempt. This is a draft, not a ruling.
What is atypical grid usage under § 19 StromNEV and how does storage help?
Atypical grid usage under § 19 (2) sentence 1 StromNEV applies when a site's maximum electricity draw falls outside the high-load time windows (Hochlastzeitfenster) published by the grid operator – i.e. when the peak-load contribution predictably and significantly deviates from the simultaneous annual peak load. This creates an entitlement to an individual, reduced grid charge of at least 20 percent of the regular charge. A large-scale battery shaves the load peaks within the high-load windows and shifts the draw into low-cost periods – making the materiality threshold (set per grid level) achievable. The determination draft provides for transitions for these individual charges and for the baseload privilege until 31 December 2031; thereafter flexibility-based discounts are to set the standard.
From what electricity consumption does a large-scale battery pay off for peak shaving?
What matters is not the consumption volume alone but the load profile: peak shaving delivers the greatest benefit with a volatile load profile featuring pronounced peaks. A precondition for the optimisation is registered load metering (RLM) in a 15-minute load profile, which is mandatory anyway from 100,000 kWh annual consumption. As a rule of thumb, deploying a large-scale battery becomes economically attractive from around 500,000 kWh annual consumption, because peripheral costs such as foundation and cabling fall proportionally as the installation grows (economies of scale).