Understanding MiSpeL: The New Regulatory Framework for German Co-located Storage

2026 Update: MiSpeL was finalised on 1 October 2026. See what it’s worth for a large-scale co-located battery.

Key points

• MiSpeL (Market Integration of Storage and Charging Points) lets co-located batteries in Germany charge from the grid. Under the earlier innovation auctions, batteries could only charge from the co-located renewable asset to benefit from levies.
• MiSpeL has two pathways. The Delineation Option (Abgrenzungsoption) measures energy flows precisely. The Flat Rate Option (Pauschaloption) is a simplified alternative for households with solar systems of up to 30 kWp.
• Energy flows are allocated every 15 minutes into three categories: direct PV export, time-shifted PV export and grid-to-grid energy.

On this page

• The shift to flexible co-location
• What are the three energy categories?
• Maximising revenue through netting
• Modelling MiSpeL with Gridcog
• FAQs
• Sources

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The new MiSpeL (Market Integration of Storage and Charging Points) regulation is fundamentally changing how co-located battery assets operate and generate revenue in Germany. By allowing for multiple commercial options, the framework enables projects to shift renewable energy and capture additional revenue across various markets through bi-directional charging.

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Historically, Germany supported co-located storage via innovation auctions. However, these auctions carried a significant constraint: to benefit from levies, batteries could only be charged by the co-located renewable asset. Charging from the grid was strictly prohibited.

This restriction limited wholesale arbitrage, multi-market optimisation, and ancillary service stacking. Developers were often forced to choose between a simple supported model with limited upside or a fully merchant model with significantly higher market risk.

The shift to flexible co-location

Following several EEG updates, particularly the 2025 Solar Peak Act, Germany established the legal foundation for more flexible co-located storage. MiSpeL acts as the regulator’s framework to put these rules into practice.

There are two primary pathways under MiSpeL:

1. The Flat Rate Option (Pauschaloption): Designed for smaller scale assets.
2. The Delineation Option (Abgrenzungsoption): A precise measurement of energy flows within the site used for settlement.

While MiSpeL applies to various combinations of generation and charging assets, the benefits are most easily seen in a standard solar and battery configuration.

What are the three energy categories?

Energy flow allocation under MiSpeL occurs at a 15-minute resolution, categorising energy into three distinct streams.

1. Direct PV export

This is solar energy produced and exported within the same quarter-hour. After accounting for any simultaneous battery charging, this volume is classified as förderfähige Netzeinspeisung. It remains eligible for the market premium, which tops up market revenues to a fixed support level.

2. Time-shifted PV export

This involves solar energy stored in the battery and exported to the grid at a later time. While this energy is no longer eligible for a market premium, its renewable origin can be proven via quarter-hour data. It is classified as saldierungsfähige Netzeinspeisung. These volumes can be netted against grid imports when calculating levies.

3. Grid-to-grid energy

This refers to energy imported from the grid, stored in the battery, and later exported back to the grid. These volumes are typically subject to non-commodity costs, including taxes and surcharges.

Maximising revenue through netting

Under the new regulation, volumes can be netted off with time-shifted solar energy. For every kilowatt-hour of nettable (saldierungsfähigen) export, one kilowatt-hour is removed from the non-commodity cost base of grid imports. The export itself receives no direct subsidy. Instead, its value is derived from avoided charges.

This creates a "middle ground" for developers. You no longer have to choose between a strictly "green-only" battery that cannot import from the grid and a fully merchant project. MiSpeL enables:

• Increased operational flexibility.
• Higher optimisation potential.
• Reduced market risk compared to pure merchant models.

Modelling MiSpeL with Gridcog

At Gridcog, we model these outcomes transparently through asset level flows. We can assign distinct pricing to direct solar export, solar export via the battery, and direct battery arbitrage with the grid. 

Modelling interasset flows in Gridcog

This allows you to compare different scenarios before making final investment or bidding decisions.

If you're interested in modelling the MiSpeL regulation in your energy projects, reach out to the team to discuss.

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FAQs

Sources

1. Bundesnetzagentur, ‘Festlegung zur Marktintegration von Speichern und Ladepunkten (MiSpeL)’, Az. 618-25-02, 1 October 2026
2. Bundesnetzagentur, ‘Bundesnetzagentur erlässt Festlegung zur Marktintegration von Stromspeichern und Ladepunkten (MiSpeL)’, press release, 1 October 2026
3. Bundesnetzagentur, ‘Hintergrundpapier: MiSpeL – BNetzA eröffnet die aktive Nutzung von Speichern und bidirektionalen Ladepunkten’, 1 October 2026
4. Prometheus Rechtsanwaltsgesellschaft, ‘Update: “Dornröschen tanzt” – Bundesnetzagentur veröffentlicht MiSpeL’, 7 October 2026
5. Taylor Wessing, ‘Draft legislation for market integration of storage and charging points’, October 2025
6. KPMG Law, ‘MiSpeL-Entwurf: Neue Förderung für Energiespeicher und Ladepunkte’
7. Energy-Storage.news, ‘Germany federal network agency picks 490MW of solar-plus-storage from oversubscribed tender’