Paragraph 14a – We clarify your 12 most burning questions

It is true that most impacted actors, including German citizens, have probably been aware of this paragraph since the heated debates in 2023, two consultation phases, countless headlines and ultimately the long-awaited announcements by the Federal Network Agency (BNetzA) on the regulation. However, the topic is still shrouded in misconception and misunderstanding, bringing about a clear need for further explanation of the specific details. We have therefore joined forces with Power Plus Communications AG (PPC), a leading manufacturer of smart meter gateways and communication technology, to clarify the most frequently asked questions from energy players, resolve uncertainties and remove the fog of uncertainty on the subject.

A quick recap: What does paragraph 14a mean?

Paragraph 14a (or § 14a or Section 14a) has been part of the Energy Industry Act (EnWG) since 2011. With its new provisions on paragraph 14a of the EnWG, the BNetzA has published how controllable energy-consuming devices will be dealt with in the future and governed what households and energy players, including technology manufacturers, distribution system operators (DSOs) and meter operators, can expect from the start of 2024, as well as what remuneration customers receive for enabling § 14a.

Here are our top 12 FAQs where we clarify the biggest ambiguities surrounding paragraph 14a:

1. Can the grid operator switch off controllable energy-consuming devices (e.g. heat pump or wallbox) completely?

Don't panic. From now on, the grid operator may only dim the consumption of controllable devices to a minimum of 4.2 kilowatts (kW) as a last resort in the event of an imminent overload of the power grid. The new provision thus ensures stable power supply even when the distribution grid is heavily utilized. Appliances are not allowed to be completely switched off, meaning they can always continue operation. An EV, for example, would still achieve a range of around 50 kilometres in two hours if its power is restricted in an emergency situation under 14a. Devices with a rated output of less than 4.2 kW are not affected by the regulation.

2. How does paragraph 14a affect end users?

End consumers are entitled to reduced grid utilization fees immediately after registering new controllable energy-consuming devices. There are two options for compensation: 

• Module 1 with a flat-rate compensation of around 150 euros (80 euros + stability premium; the amount depends on the grid operator). Time-variable grid charges can be added as an option from 1st April 2025. 
• Module 2 includes a 60 per cent reduction in the energy price. To enable this, an additional metering device must be installed. Module 2 is particularly worthwhile if the consumption of the devices exceeds around 3,100 kWh/year. 

In addition, the grid operator may no longer delay or reject the grid connection of new controllable consumers due to a lack of grid capacity, but must directly accept new applications. Immediately after receiving the application, the DSO can instruct the meter operator to establish controllability. As a rule, the grid operators provide online forms for registering or applying for the connection/installation of new controllable devices. This is used to request the necessary information from end customers and start the corresponding process.

3. Does a separate/additional contract have to be concluded between the DSO and the device operator due to taxability and reduced grid fees?

The conclusion of a separate or additional contract between the DSO and operator is not mandatory. The mere granting of reduced grid charges is considered sufficient. However, an additional contract is possible. 

4. What are the benefits of an energy management system (EMS) under paragraph 14a?

In short: Maintaining the comfort of a household after ‘dimming’ through self-generation and storage.

An energy management system (EMS) can be used to include self-generation from a photovoltaic (PV) system in the consumption analysis. The noticeable effects of dimming can be minimized by intelligently distributing the maximum power value among all consumption devices with the help of the EMS. In addition, an EMS can document the implementation of grid-friendly control.

5. Is a smart metering system absolutely necessary?

Yes, smart metering systems will be the prerequisite for secure control actions by a grid operator from 1st January 2024. Smart metering systems consist of a smart meter and a communication interface, also known as a smart meter gateway (SMGW). In addition, from 1st January 2025 at the latest, end consumers can request the installation of a smart metering system from the meter operator if none has been installed by that date. The installation must then take place within four months.

6. Which consumers must be connected to the grid in accordance with paragraph 14a EnWG? Is this voluntary?

All newly installed systems are obliged to participate in consumption control in accordance with paragraph 14a as of 1st January 2024 – provided their grid connection capacity exceeds 4.2 kW in total for heat pumps and room cooling or individually for other assets, and a direct or indirect connection is made with the low voltage grid (grid level 6 or 7).

• Charge points for electric cars that are not publicly accessible charge points according to Section 2 No. 5 of the Charging Point Ordinance.
• Heat pump heating systems, including auxiliary or emergency heating devices (e.g. heating elements).
• Systems for room cooling.
• Systems for storing electrical energy (electricity storage) with regard to electricity consumption.

But beware, there are exceptions: there is no consumption control in bottleneck situations for assets installed by authorities and organizations entrusted with security tasks; those that are considered critical infrastructure; or those that serve operationally crucial purposes.

7. What if my devices were installed before 01.01.2024?

Consumption devices with or without an existing paragraph 14a agreement (installed in 2023 or before) will be transferred to operation that abides by the new paragraph 14a regulations between 1st January 2024 and 1st January 2029. A voluntary switch is possible from now. Night storage heaters are not affected. Under the new paragraph 14a regulation, they will no longer be regarded as controllable energy-consuming devices from 1 January 2024. Existing § 14a regulations (2023 and earlier) can be maintained until the night storage heating system is decommissioned.  

8. Do devices that are connected to a smart meter gateway (SMGW) need to be certified?

Devices that are connected to the CLS interface of the smart meter gateway must meet the requirements of BSI Technical Guideline TR-03109-5 for the secure connection of CLS components to the smart meter gateway from 1st January 2024. Proof must be provided from 1st January 2025 at the latest by successfully completing a certification procedure; until then, proof can be provided by means of a manufacturer's self-declaration. An EMS can also be CLS-capable and operated on a certified CLS component so that it can be directly connected to the smart meter gateway.

9. How does the communication connection between SMGW and EMS work?

The EMS can be connected directly to a SMGW, provided it is CLS-capable and certified in accordance with TR-03109-5. Alternatively, the EMS can be connected behind a CLS communication adapter (e.g. CLS gateway). In the future, it will also be possible to transmit control specifications directly from the SMGW to an EMS. Accordingly, the BNetzA stipulates that from now on design specifications must consider the consumption devices’ functions, which are integrated into the SMGW and other technical developments.

10. When is a device compatible with § 14a and what does the technical interaction between SMGW and EMS look like?

A device is paragraph 14a-compliant if it can be proven that it follows control signals. Control capability can be achieved in various technical ways. Systems that support the digital EEBus interface (with the corresponding use case) are considered future-proof and compliant. If a ‘translation function’ is integrated in the EMS, a control signal received in EEBus format can also be sent to systems without an EEBus interface. Communication between the SMGW and EMS takes place via EEBus and between the EMS and, for example, the charging station via a different communication protocol. The control signals (e.g. dimming to 4.3 kW) and the smart meter’s current measured values are exchanged between the SMGW and EMS (or SMGW, control box and EMS). The EMS requires these signals and values for dynamic self-consumption optimization.

11. The control measures should be non-discriminatory. How can an end customer understand this? 

The new regulations under paragraph 14a require grid operators to document all necessary information about the grid status assessment and details of measures. They must keep this information for at least two years. Likewise, from 1st March 2025 at the latest, all DSOs must transparently publish the scope, type and duration of control measures in grid areas on a joint internet platform. This enables end customers to transparently track control measures. Independent thereof, an EMS will also be able to display current and historical control measures for end customers and transparently present possible impacts.

12. Can cloud EMS concepts also be used in addition to local EMS?

A local EMS enables the limitation of a control measure to be considered in the optimization of self-consumption with little or no impact to the comfort of the end user. PV generation in particular can be used to optimize energy flows. This makes it possible, for example, to keep the power constant during a charging process even if consumption is being restricted. The use of a cloud EMS concept, in which the control algorithms are executed on cloud servers and no local hardware is used, is considered extremely challenging. Regulatory and safety requirements, such as the use of real-time smart meter measurement data or the processing of dimming signals, make Cloud EMS particularly difficult to implement at present.

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Still have questions? Take a look at our expert tip, wherein a gridX expert breaks down the effects of paragraph 14a EnWG at a household level.