MiSpeL, AgNes & Co.: The State of V2G Regulation in Germany

Bidirectional charging, particularly Vehicle-to-Grid (V2G), is ready for the market: vehicles, bidirectional chargers and backend systems have been tried and tested, and the first commercial applications are already operating successfully. However, if electric vehicles are to be used as mobile energy storage systems on a broad scale, the regulatory framework must also be fit for purpose.

For a long time, that was not the case in Germany. Laws and regulations prevented EV owners and the power grid from benefiting from the advantages of V2G.

The reason was that electricity charged from the grid into a vehicle battery and later fed back into the grid was effectively subject to multiple charges: grid fees, electricity tax and green energy levies (EEG levies). These charges applied both when the electricity was imported into the battery and when it was discharged, in other words: when the energy was fed back into the grid. This made V2G economically unattractive. Paradoxically, stationary battery storage systems were exempt from this double burden.

Since the beginning of 2026, lawmakers and the Bundesnetzagentur (BNetzA), Germany’s energy regulator, have been working to place stationary and mobile energy storage systems on an equal regulatory footing. Four aspects are particularly relevant to V2G:

1. Grid fees: An amendment to the Energiewirtschaftsgesetz (German Energy Industry Act; EnWG for short) eliminates the double charging of grid fees when electricity is imported from and fed back into the grid. In this respect, electric vehicles are finally treated like stationary storage systems. This change made V2G economically viable in Germany for the first time.
2. Electricity tax: The amended Stromsteuergesetz (Electricity Tax Act) protects private vehicle owners from what is known as the “supplier trap.” In other words, participating in V2G does not legally turn them into electricity suppliers—with the additional tax, documentation and billing obligations that this would entail.
   However, an exemption from electricity tax on electricity fed back into the grid is tied to self-generated solar power. Anyone who stores electricity from the grid in their vehicle battery must continue to pay electricity tax.

3. Market integration: The BNetzA’s determination on the “market integration of storage systems and charging points” (Marktintegration von Speichern und Ladepunkten; MiSpeL for short) is intended to establish rules for distinguishing, for accounting purposes, between different volumes of electricity in storage systems and bidirectional charging points operated in combination with other assets.
   More specifically, the rules concern the distinction between electricity from renewable sources and electricity drawn from the public grid. This distinction is important because it allows an electric vehicle operating in V2G mode to take in electricity and feed it back into the grid later without automatically jeopardising the eligibility for support or potential levy exemptions associated with the renewable share of the electricity.
   MiSpeL is scheduled to take effect on 1 October 2026. A transitional period is planned to run until 30 September 2027. During this period, the rules may only be applied with the agreement of the relevant distribution system operator and metering point operator.

4. The grid fee system: The Allgemeine Netzentgeltsystematik Strom (General Electricity Grid Fee System; AgNes for short) is intended to fundamentally reform how grid fees are calculated from 2029 onwards. One planned change that is particularly relevant to V2G concerns grid electricity fed back into the network. It is intended to be exempt from usage-based grid fees, provided that it can be clearly distinguished from other electricity flows through appropriate metering. This could allow bidirectional charging points to be treated similarly, for grid fee purposes, to stationary storage systems coupled with a generation facility.
   The draft AgNes determination has been available since early August 2026, and the consultation is scheduled to run until 18 September 2026.

Taken together, these four areas form the regulatory framework for V2G in Germany. Overall, the measures are moving in the right direction. However, one key regulatory obstacle remains to be overcome before V2G can be scaled up widely.

The current version of MiSpeL overlooks the simplest and most important V2G use case for the mass market: households with an EV and a bidirectional charging point, but without a photovoltaic system or stationary home battery.

MiSpeL provides two ways of accounting for charging points when distinguishing between different volumes of electricity and determining eligibility for support and levy exemptions: the Abgrenzungsoption and the Pauschaloption.

The Abgrenzungsoption (delineation option) treats charging points in the same way as stationary battery storage systems: the electricity charged and the energy fed back into the grid are attributed to the charging point.

The basic approach makes sense. In practice, however, it requires an accurate record of how much electricity is charged from the public grid into the vehicle and how much is subsequently fed back into it. This generally requires two separate meters.

For private households, this creates an additional technical and financial hurdle. A second smart meter can cost between €1,000 and €3,000 for the equipment and installation alone and results in ongoing annual costs of around €100. In many existing buildings, it also requires a larger meter cabinet. If V2G generates a realistic annual benefit of €500 to €700, the metering equipment alone will take years to pay for itself.

That is not a viable solution for the mass market.

The Pauschaloption (flat-rate option) is intended to simplify metering. Instead of measuring and tracking every kilowatt-hour with 15-minute precision, it operates using generalized assumptions and fixed formulas. This requires only one smart meter.

Under the current version, however, it is available only for certain configurations, involving a stationary home battery. It is not available for the simplest V2G use case.

The flat-rate option also includes what is known as an Indifferenzbereich (indifference range). This limits the share of electricity fed back into the grid that may be offset against electricity previously drawn from the grid at the same connection point.

For V2G households with a solar system but without a home battery, MiSpeL applies a flat-rate factor of 0.5. Because of this rigid flat-rate reduction, a large share of the electricity fed back into the grid is not taken into account for either eligibility for support or offsetting purposes, where no EEG support is claimed at all.

A simple comparison illustrates the economic impact: An EV owner who uses their battery for V2G within the usual limits approved by the vehicle manufacturer can generate an economic value of around €500 to €700 per year. For households without a stationary home battery, this value falls to just €50 to €70 per year as a result of the rigid flat-rate reduction.

Without an additional home battery, V2G would therefore hardly be economically viable. Even though the legislature has placed stationary and mobile electricity storage systems on an equal footing, MiSpeL still treats them completely differently.

These hurdles and generous safety buffers stem primarily from fears of abuse—such as drivers charging cheaply elsewhere and then generating levy-free revenue at home or engaging in pure arbitrage without providing any benefit to the grid.

In practice, however, these fears are not justified. Here's why:

1. Physical safeguards: V2G products are designed so that the vehicle is never discharged below its state of charge when it arrived at home. This means that the energy fed back into the grid comes from electricity drawn at home.
2. Grid fees have already been paid: Grid fees are also charged when the vehicle is charged elsewhere, for example at the workplace.
3. Technical limitations: Efficiency losses of around 15%, together with manufacturer-imposed safeguards for the vehicle battery, make pointless “back-and-forth” energy transfers economically unattractive. Moreover, any offsetting is strictly capped by the household’s electricity consumption from the grid.

Against this backdrop, a factor of 0.5 for bidirectional charging points without a stationary home battery is disproportionate.

MiSpeL is still only a working draft. The rules can therefore still be made more practical and more supportive of V2G.

As the technical partner in many V2G projects, we believe that three aspects of MiSpeL should be revised:

• The one-meter route must also be made available to V2G-only households: The Pauschaloption’s simplified rules should apply to bidirectional charging points, regardless of whether a household has a PV system.
• The indifference range for bidirectional charging points must be removed: It is not appropriate to the actual V2G use case and places a disproportionate burden on the market ramp-up.
• Mobile and stationary storage systems must be treated equally: If lawmakers have determined that a vehicle battery is legally a storage system, the regulator’s calculation methodology must not contradict that decision.

All major German car manufacturers have launched or announced V2G offerings. For them and their partners, these regulatory issues are far from being a side matter. They will determine whether Vehicle-to-Grid becomes easily accessible and economically attractive for customers—or whether additional meters, complex metering arrangements and unclear tax implications delay the market’s expansion by years.

Regulation must not put the simplest and potentially most common use case at a disadvantage compared with more complex configurations involving a PV system and a stationary home battery. V2G-only households (with an electric vehicle and a bidirectional charging point) could form the backbone of the mass market.

Unnecessarily complex rules would harm not only the businesses and consumers involved, but also the energy transition. V2G has enormous potential to relieve pressure on the grid, support the integration of renewable energy and create an additional selling point for electric vehicles.

The essential regulatory framework for V2G in Germany is now in place. What is needed is one final round of fine-tuning to allow the market to scale.