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EEG amendment 2021: How should things go on with over 20 systems?

Attention: Much of the information in this article has changed with the EEG amendment in 2021. Please read our current publications in the "Energy Policy" menu.


Operators of solar and wind power systems, whose entitlement to remuneration is about to expire, are desperately expected to follow-up regulations for economically viable and practicable continued operation. For ecological and climate policy considerations, this would be urgently necessary, because it is hard to see why properly functioning RE systems should not remain connected to the grid. A lack of connection solutions would be a serious mistake in the case of an energy transition that is making slow progress and is characterized by a loss of confidence.

Particularly in the case of over 20 PV systems, the current legal situation is not acceptable. According to the current EEG 2017, continued operation is only possible if system operators directly market the electricity fed into the public grid without funding from the EEG (so-called other direct marketing). In addition, a 40% EEG surcharge is due for every kilowatt hour of self-consumption.


The SFV has already commented on this problem in several articles, lectures, in an expert opinion and in public petitions:

Among other things, old PV systems: ensuring continued operation after the remuneration has expired?

Expert opinion: Services and costs for the continued operation of old PV systems

among others in Berlin, Aachen, Soest, Freckenhorst, Amberg, Roding, Wemding etc. and in online seminars,

No OFF for solar systems after 20 years
We now need a right to solar self-sufficiency!


Bill for the EEG 2021

On September 23, 2020, the Federal Cabinet passed the amendment to the Renewable Energy Sources Act introduced by Federal Economics Minister Peter Altmaier, the so-called EEG Amendment 2021. It is to be passed in the German Bundestag in the 2nd and 3rd reading before Christmas.

The draft law can be downloaded here as a PDF file.

Offer for over 20 solar systems in the planned EEG 2021

(without claim to completeness, not legally binding)
  • The Entitlement to network connection should remain.
  • For systems up to a maximum of 100 kW there should be one Entitlement to feed-in tariffs give. To determine the amount, the annual market price should be used as the value to be applied per kilowatt hour. For 2020, the forecast is below 2.5 cents / kWh.
  • From the value of the feed-in tariff to be applied, a Share for marketing deducted. This is 0.4 cents / kWh.
  • The deduction of 0.4 cents / kWh is reduced by 0.2 cents per kilowatt hour if an intelligent measuring system (iMSys) - smart meter - is installed.
  • The feed-in tariff should maximum until 2027 be granted.
  • Full feed: System operators must provide the network operator with all of the electricity generated in the system as long as no intelligent measuring system (iMSys) - smart meter - is installed.
  • Ownconsumption: If plant operators want to use the electricity themselves, they have to install iMSys.
  • Penalties If plant operators use the electricity themselves without installing an iMSys, a penalty is due. This should correspond to the labor price in the supply area.
  • For every kilowatt hour of self-consumption - regardless of the size of the system - the 40% EEG surcharge is due.
  • (other) direct marketing: Electricity fed into the grid can be marketed directly. There is no entitlement to funding (market premium). The condition for direct marketing is the use of iMSys for billing and balancing the electricity.
  • Transitional regulations for intelligent measuring systems: The currently available iMSys cannot yet be remotely controlled. The necessary official market declaration for compulsory installation is also missing. As long as both are not yet available, plant operators should use existing digital measurement technology, which can later be expanded to the full functionality of iMSys.


The planned remuneration regulations for PV systems after the 20-year remuneration has expired are an economic disaster for the pioneers of the energy transition. With a feed-in tariff in the amount of the annual market price, the continued operation of full feed-in systems is not economically reasonable. The annual operating costs for insurance, maintenance and meters are not even remotely covered. The compulsory installation of smart meters for self-sufficiency and the threat of penalties if this obligation is not fulfilled add to the irresponsibility of the authors of the draft bill. Obviously, one accepts that about 1 gigawatt of solar energy will go off the grid by 2025. Mind you: These are perfectly working solar systems that could produce climate-neutral electricity. That is a serious mistake in the case of a sluggish energy transition that is characterized by a loss of confidence.