In its position paper on the 2027 amendment to the Renewable Energy Act (EEG), the ZVEH advocates retaining the feed-in tariff for PV systems under 25 kWp. The association also calls for reliable framework conditions for system operators, customers, and specialist companies.
The ZVEH critically assesses key points of the draft EEG amendment. In particular, the planned abolition of the feed-in tariff for smaller PV systems and the obligation to engage in direct marketing could trigger a significant market slump, the association warns. Instead, it urges reliable framework conditions, practical market models, and accelerated expansion of grids, storage systems, and smart meters.
“For a successful energy transition, we need reliability. Limiting subsidies for newly built small plants to just three years—with no guarantee of extension—does not provide the necessary security, especially since direct marketing remains unrealistic for many operators,” — Alexander Neuhäuser, Managing Director of the ZVEH
Feed-in Tariff: A Necessity for Small Systems
The ZVEH supports keeping the feed-in tariff for systems below 25 kWp. The draft proposal’s transitional payment of 5.2 cents per kWh for three years is, in the association’s view, an insufficient basis for investment decisions. Additionally, the possibility of a non-binding extension by the Federal Network Agency does not offer adequate long-term security.
A de facto elimination of the feed-in tariff, the ZVEH argues, would lead to a sharp decline in PV investments, particularly in the residential sector. This would not only jeopardize the energy transition but also threaten jobs in the skilled trades and regional value creation. As an alternative, the association proposes increasing the annual degression rate for new plants from 2% to 4% rather than abolishing the tariff entirely.
Direct Marketing: Not Yet Ready for the Mass Market
The ZVEH also rejects the planned direct marketing requirement for systems up to 100 kW in its current form. According to the association, the technical and regulatory prerequisites for a functional market in small-scale PV are still missing. The proposed direct marketing bonus (limited to four years) would not solve this issue, as it would impose excessive bureaucracy on plant operators while failing to provide sufficient investment security.
Instead, the ZVEH calls for simplified, standardized, and cost-effective models for direct marketing, energy sharing, and tenant electricity—making them truly viable for the mass market. Tenant electricity models, in particular, must be more secure and streamlined to ensure equal participation in the energy transition for renters.
Grid Connection & Flexibility: Key Adjustments Needed
The ZVEH supports aligning legal limits with the actual power fed into the grid at the connection point—rather than solely with a plant’s installed capacity. What matters for grid impact is the power actually injected, not the theoretical maximum. This approach would allow more flexible and cost-effective designs for systems, storage, and on-site consumers.
The association also criticizes the proposed redispatch reservation regulations. It argues that compensation claims for redispatch should remain unchanged for now, and that electricity usable before the grid connection point should not go to waste. Operators should have the freedom to choose whether curtailment occurs at the plant or at the grid connection point.
Accelerating Infrastructure: Grids, Storage, and Smart Meters
Beyond PV-specific regulations, the ZVEH demands faster expansion of grids, storage systems, and smart meters. This requires: binding targets, clear timelines, and assigned responsibilities, effective oversight and transparent progress tracking.
The association also stresses the importance of retaining zero feed-in options, enabling subscribers and operators to design generation, self-consumption, and storage economically. Additionally, it calls for targeted expansion of energy management systems in customer installations to improve grid-friendly control and flexibility in the future.
