DATELINE: BERLIN, OCTOBER 21, 2026

The Reform of Redispatch 2.0: bne Welcomes Progress but Warns of Digitalization Gaps and Market Friction

In a significant move to stabilize the German electricity market and refine the mechanics of the energy transition, the Association of New Energy Business (bne – Bundesverband Neue Energiewirtschaft) has issued a comprehensive statement regarding the Federal Network Agency’s (BNetzA) latest determination process. The proceeding, designated as GBK-25-01-1#1, focuses on determining the appropriate compensation for expenses incurred during the balancing of Redispatch measures—specifically within the "forecast model" utilized by Distribution System Operators (VNBs).

While the bne broadly supports the BNetzA’s efforts to reform a system currently riddled with false incentives, the association highlights critical deficiencies in digitalization and warns that the current cost-based approach is increasingly at odds with European Union market standards.

1. Main Facts: A Shift Toward Fairness in Grid Management

The core of the BNetzA’s proposed reform aims to rectify long-standing inequities in how Redispatch—the intentional adjustment of power generation to prevent grid bottlenecks—is accounted for. Under the previous regime, direct marketers often bore the financial brunt of errors made by grid operators. If a VNB transmitted faulty Redispatch signals, the resulting balancing costs were frequently offloaded onto the Balance Group Managers (BKVs).

Key highlights of the bne’s position include:

• Price Reference Reform: The bne applauds the transition to the Intraday-AEP (ID-AEP) as the new price reference, replacing the outdated ID1-Index.
• Overhead Compensation: For the first time, a flat-rate "Overhead Pauschale" of €1.35 per MWh is proposed to compensate BKVs for the administrative and IT burdens of managing Redispatch.
• Incentive Systems: A new penalty system for VNBs aims to ensure timely reporting of Redispatch measures, with a proposed tolerance threshold of 20% of total annual lost energy (Ausfallarbeit).
• The Digital Deficit: The bne’s sharpest criticism is reserved for the lack of a mandated central data exchange and clearing portal, which the association deems essential for "mass-business" scalability.

2. Chronology: The Long Road to Redispatch 2.0 Stability

To understand the weight of the October 2026 statement, one must look at the evolution of German grid management:

• 2021: The Launch of Redispatch 2.0. The initial rollout expanded Redispatch obligations from large conventional plants to smaller renewable installations (above 100 kW). However, the implementation was plagued by data exchange failures and complex billing processes.
• 2022–2024: The "Forecast Model" Crisis. VNBs struggled to accurately predict renewable output, leading to "false" Redispatch signals. BKVs were forced to procure replacement energy at high costs without adequate reimbursement.
• Early 2025: The Consentec Report. An expert opinion by the consultancy Consentec revealed that advance notifications from grid operators were systematically missing or delayed, validating the industry’s complaints.
• Mid-2026: BNetzA Draft Determination. The Federal Network Agency released the draft for GBK-25-01-1#1, seeking to standardize compensation and introduce the €1.35 overhead rate.
• October 21, 2026: bne Official Response. The current statement serves as a formal intervention, urging the regulator to close loopholes before the determination is finalized.

3. Supporting Data: The Economics of Compensation

The bne’s analysis provides a deep dive into the numbers that will dictate the profitability of direct marketing in the coming years.

The Overhead Flat Rate (€1.35/MWh)

The proposed rate is based on a weighted average of costs ranging from €0.70 to €2.60 per MWh. While the bne supports the introduction of this rate, they argue that fixing it until the end of 2031 is a mistake.

• Data Point: Personnel and IT costs in the energy sector are projected to rise significantly by 2030 due to the complexity of integrating Co-location battery storage.
• Recommendation: The bne demands a mandatory review of this rate in 2028 and 2030 to ensure it reflects the actual economic environment.

The Mixed-Price Dilemma

The BNetzA proposal introduces a "mixed price" for compensation, consisting of 72.5% ID-AEP and 27.5% reBAP (the grid-wide balancing energy price).

• The Risk: This average assumes that "over- and under-recoveries" will balance out over time. However, the bne points out that if a specific VNB is habitually late with notifications, the BKV in that region will suffer a permanent financial deficit.
• Tolerance Threshold: The 20% threshold for late notifications is seen as a starting point, but the bne insists it should drop to 10% by 2030 to force grid operators to modernize their communication.

4. Official Responses: bne’s Critique of the Status Quo

The bne’s statement serves as a stern reminder that administrative efficiency is as vital as physical grid stability.

On the Lack of a Central Portal:
The bne describes the absence of a central clearinghouse as "unproportional" and inefficient. "A central portal is required for standardized and digitalized clearing processes both up to 2031 and beyond," the statement reads. Currently, BKVs must navigate various internet platforms of different VNBs to verify data, a process that is not fit for the "mass-transaction" nature of modern energy trading.

On "Phantom" Redispatch:
A particularly technical but vital grievance involves the "A96" notification. Grid operators often announce a measure but then fail to execute it or do so at a lower volume.

• The Problem: The BKV has already bought the replacement power based on the announcement. If the measure isn’t executed, they receive no compensation under the current draft.
• The bne Demand: Compensation must be granted for the difference between announced and actual energy curtailment, using the reBAP price, as the BKV cannot "un-buy" that position on the market.

On Cascaded Networks:
The bne identified a loophole where VNBs could dodge penalties by claiming a measure was requested by a "higher-level" Transmission System Operator (ÜNB). The bne insists that delays within the communication cascade between grid operators should never be the financial responsibility of the direct marketer.

5. Implications: Toward a Market-Based Future

The bne statement concludes by looking at the "Big Picture"—the fundamental tension between German national law and European Union regulations.

The Legal Conflict (EnWG vs. EU EB-VO)

Under Section 13a of the German Energy Industry Act (EnWG), Redispatch is a cost-based system. However, the EU’s Electricity Balancing Regulation (EB-VO) and the upcoming Network Code Demand Response mandate market-based procurement as the default.

• The Implication: Germany is building an increasingly complex "repair shop" of regulations to fix a cost-based system that should, by EU standards, be replaced by a competitive bidding process.
• Flexibility Loss: By sticking to cost-based models, Germany is failing to unlock the full potential of "Demand Side Response" and flexible loads. Market-based models, used successfully in the UK and the Netherlands, mobilize flexibility more efficiently and make opportunity costs visible.

The Integration of Co-location Storage

As Germany approaches its 2030 climate targets, the role of batteries located at renewable sites (Co-location) is paramount. The bne warns that these assets are currently not adequately represented in the Redispatch "target model."

• The Solution: Transitioning these assets into the "Plan Value Model" with full balance compensation before 2031 is essential. This would significantly reduce the "short-term bottleneck findings" that currently plague transmission operators.

Conclusion

The bne’s response to the BNetzA is a call for a more professional, digitalized, and market-oriented grid. While the €1.35 overhead rate and the ID-AEP price reference are welcomed as long-overdue corrections, the association warns that without a central clearing portal and a transition toward market-based flexibility, the German Redispatch system will remain a source of administrative friction and financial risk for the very companies driving the energy transition.

The Federal Network Agency now faces the task of deciding whether to implement these "repairs" or continue with a draft that the bne views as a missed opportunity for true modernization.