Grid Jarvis · Blog

Period quotas in Germany's smart meter rollout: the final weeks before 31 December 2026

Mid-December, in the cellar of an apartment building. The technician fits two modern metering devices (moderne Messeinrichtungen) with a smart meter gateway and takes the photos. Then the work order is reported as done. That day, nobody notices that the gateway can't get a mobile signal in the concrete cellar. On the project manager's list, the installation counts. Whether the Federal Network Agency (Bundesnetzagentur, BNetzA) will count it too is another question.

On 21 September 2026, the BNetzA announced that period quotas (Zeitraumquoten) would now be its focus. The first deadline is 31 December 2026. Installing the device alone is not enough for the agency. It has already opened hundreds of supervisory proceedings over the previous 20% quota.

What the period quota requires is quick to explain. Planning for it is the harder part, first for the final weeks of 2026, then for the 2027 to 2028 period. This post reflects the situation as of October 2026.

What § 45 MsbG requires

Since 25 February 2025, § 45 of Germany's Metering Point Operation Act (Messstellenbetriebsgesetz, MsbG) has set period quotas for the mandatory rollout by the default metering point operators (grundzuständige Messstellenbetreiber, gMSB).

§ 45(1) sentence 1 no. 4(b) covers final consumers who use more than 6,000 and up to 100,000 kWh a year. It also covers 14a cases, meaning cases with a controllable consumption device under § 14a of the Energy Industry Act (Energiewirtschaftsgesetz, EnWG). Between 25 February 2025 and the end of 31 December 2026, the gMSB must equip at least 90% of the metering points that fall due for equipping in that same period ("im Zeitraum vom 25. Februar 2025 bis zum Ablauf des 31. Dezember 2026 bei mindestens 90 Prozent der in diesem Zeitraum neu auszustattenden Messstellen").

Going by the wording of the law and the BNetzA's reading, only metering points that became mandatory cases during this period count. We call these "new cases" below. According to the BNetzA's survey form for the first half of 2026, these are existing metering locations that become mandatory through higher consumption or a new 14a device, and new metering locations that are mandatory from the start. The annual consumption check under § 30(4) MsbG keeps adding cases.

Generation plants above 7 kW and up to 100 kW are counted by installed capacity under no. 2(a), not by the number of plants. By 31 December 2026, plants making up at least 90% of the capacity commissioned between 25 February 2025 and 30 September 2026 must be equipped. So the list of plants that count is already fixed.

Competitive metering point operators (wettbewerbliche Messstellenbetreiber, wMSB) have no quota of their own. If they don't equip a mandatory metering point within four months of the retrofit notice, the obligations stay with the gMSB (§ 36(1) MsbG).

What the Federal Network Agency reported on 21 September 2026

The figures refer to the reference date of 30 June 2026 (press release, rollout page):

  • 26.1% of mandatory installation cases (6,000 to 100,000 kWh, including the 14a cases) are equipped: 1,259,270 of 4,831,178, across 803 gMSB. This is the overall rollout figure, not a period quota.
  • Supervisory proceedings against 434 companies have been opened since March 2026 over the 20% quota due by 31 December 2025. In 77 of these cases the quota was 0%, and 150 have since been discontinued.

As of 7 October 2026, the BNetzA had not published period quotas per company, and it was not yet known when it would collect the data for 31 December 2026. It can enforce its orders with a coercive fine (Zwangsgeld) of €1,000 to €10 million (§ 94 EnWG read with § 76(4) MsbG). A coercive fine is meant to force compliance. It is not an administrative fine for an offense (Bußgeld).

Installed does not mean equipped

According to the BNetzA, installing a smart metering system (intelligentes Messsystem, iMSys) alone does not meet the obligations. The devices must reliably record and transmit 15-minute values.

The survey form is explicit about 14a cases and plants. The metering point only counts as equipped once the control device is integrated into the metering point operator's systems and ready for operation. One exception: plants whose feed-in is permanently limited to 0% need no control device once the operator has declared this in text form (Textform, § 29(5) MsbG).

By 7 October 2026, the BNetzA had not published how it checks that all other iMSys actually deliver data.

Working back from the deadlines

§ 37(2) MsbG requires those affected to be informed at least three months before the installation. Counting back, an installation on 31 December 2026 needed the notice to arrive by the end of September 2026. Check this for every open new case. Ask a lawyer what applies to new buildings, and what it means for the quota if an installation was announced late.

§ 38 MsbG governs access. It requires written notice at least two weeks before the appointment, sent to the connection user (Anschlussnutzer, usually the occupant) or posted on or in the building. At least one alternative date must be offered. For an appointment on 30 December, the notice should therefore be posted, or have reached the connection user, by 15 December at the latest.

There are 38 working days (Monday to Friday) from 2 November, the first working day of the month, to 23 December 2026. In Saxony there is one fewer, because of the Day of Repentance and Prayer (Buß- und Bettag) on 18 November. We would reserve 24 to 31 December for rework and for alternative appointments in freely accessible meter rooms, not for first attempts. Between Christmas and New Year, many residents and property managers are hard to reach.

Know what is due at every address

In our view, it pays to plan by address rather than by meter. Track the new cases in a separate list alongside your existing metering points, and keep it up to date, for example from grid connection and 14a notifications. For each address, the list should show what is due there:

  • new cases,
  • older mandatory cases that are still open,
  • 14a cases and plants above 7 kW that need an integrated control device,
  • optional cases in the same building, meaning metering points the gMSB may equip but does not have to. Under § 45(1) sentence 4, those that get an iMSys reduce the number of metering points the gMSB has to equip. The BNetzA has not published how it counts them for the period quota.

We would schedule the new cases first and, for the 2026 plant quota, start with the plants with the highest capacity. If you are already facing supervisory proceedings over the 20% quota, take that into account when you set the sequence. As a gMSB, you can agree binding priorities with the grid operator under § 45(3). That does not change the quota itself.

If you are a contractor, it is best to ask the gMSB for this list by address. Request only the details you need, and settle data protection, as a rule with a data processing agreement. A weekly report with four numbers is enough for the project manager:

  • newly due,
  • equipped and communicating,
  • installed but not communicating,
  • still open, broken down by reason.

Access through property managers and caretakers

Once notice has been given, the connection user and the connection owner (Anschlussnehmer, as a rule the property owner) must give the gMSB and the people it sends access when they show ID, to the extent the job requires. For plants, the same applies to the plant operator. All of them must also keep the metering point accessible (§ 38 MsbG). For wMSB, their contracts apply instead. Connection users and connection owners must not prevent the installation (§ 36(3) MsbG). That helps little if nobody opens the cellar at 8:00. In our view, two things help more:

  • Involve the property manager early and note a key holder for each building, such as the caretaker, in the work order. With written consent from the owner or the property manager, the meter room visit becomes a free access job, and nobody has to stay home for it. You still need the § 38 notice every time, also because the power to the affected flats is briefly cut during the meter swap.
  • Schedule the alternative date on a route day when the crew is in the neighborhood anyway. If the posted notice already shows it, fewer residents call the office.

Group visits by building and check reception first

Once you are in the meter room of an apartment building, equip every metering point that is due during that visit, provided the § 37(2) notice for each of them was received in time. If several metering locations are connected to one gateway, the survey form counts each one as a separate iMSys.

Find out what the mobile reception is like at the meter position (Zählerplatz) before the appointment, from a site survey or earlier visits. If it is weak, decide on the fix in the office, for example a remote antenna or a different WAN connection, rather than improvising in the cellar.

Only mark an installation as complete in your own system once the gateway is connected to the gateway administrator (the party that manages it remotely) and the first readings are coming in. In 14a cases and plants, the control device must also be integrated. Everything else goes on a rework list.

Document failed attempts for supervisory proceedings

Record the following for every failed appointment:

  • when and how it was announced under § 37 and § 38,
  • which alternative date was offered,
  • why it failed, for example no access, an unsuitable meter position, refusal or no mobile reception,
  • a photo of the posted notice or the locked door, without people or name plates.

Before you start, have someone check the data protection side: how long you keep these records and who can see them.

The MsbG does not expressly say that documented failed attempts reduce the quota or excuse missing it. In our view, though, clean documentation is the basis for your response when the BNetzA gives you the chance to comment (Anhörung) in supervisory proceedings.

Plan for 2027 to 2028 before the year is out

§ 45(1) sentence 1 no. 4(c) sets the same 90% rule for final consumers, covering the metering points that fall due for equipping between 1 January 2027 and 31 December 2028. Have a lawyer check what happens to new cases that are still open at the end of 2026.

No. 2(b) sets the next plant deadline, 31 December 2028. By then, plants making up at least 90% of the capacity commissioned between 1 October 2026 and 30 September 2028 must be equipped. The same applies to 50% of the capacity commissioned between 1 January 2018 and 25 February 2025. You can schedule these older plants early.

Schedule new mandatory cases as soon as they arise, and make sure the § 37(2) notice is received at least three months before the planned installation. Otherwise the end of 2028 will be tight again.

The government draft of the Renewable Energy Sources Act 2027 (Erneuerbare-Energien-Gesetz, EEG 2027) is before the Bundestag (BT-Drs. 21/7867). It would lower the threshold for plants from 7 to 2 kW and count metering points instead of capacity. The gMSB would be able to choose between the two counting methods for the quota due on 31 December 2026. To our knowledge, the draft had not been passed as of 7 October 2026. Plan under current law.

How Jarvis helps

Jarvis plans rollout projects in waves on its own, from the building down to each technician's daily route. It agrees appointments with residents and property managers by phone or SMS, and it also sends appointment letters. In the online portal, residents can confirm or move their appointment themselves, around the clock.

In the Jarvis app, technicians record the old and new meter numbers and readings, even offline in the cellar. Installation photos can be checked by AI on site. You can set up the check "gateway connected" as a fixed step in the report form. Project managers see progress in real time, with a complete history per unit. U-SERV GmbH, for example, plans and schedules its meter swap projects with Jarvis.

If you are planning your last new cases for 2026, or are already looking at 2027 to 2028, we are happy to show you what that looks like in Jarvis. Book a 15-minute walkthrough.

This article is not legal advice. For questions about your grid area, check the current text of the Messstellenbetriebsgesetz or ask a lawyer.

By Valter Pasanen, Founder, Grid Jarvis. Published 2026-10-07.