Looking at the broader trends over the past year and into the first quarter of 2025, it is evident that the transition is no longer solely focused on renewable energy generation and emissions reduction. The current phase increasingly involves diversification of energy sources and the progressive modernization of grid infrastructure. This evolution reflects the growing demand for system flexibility, a direct consequence of the rise in non-programmable energy sources. At the same time, the integration of digital infrastructure into energy grids is becoming a crucial element, enhancing grid management and enabling a smarter, more resilient energy network.

Read Here

Authors: Piero Viganò, Ernesto Rossi, Giuliano Proietto, Stefano Biraghi

This transaction is part of a broader project to repower the plant, with the aim of increasing its electricity production capacity and meeting the territory's electricity needs.

Through this acquisition, Albioma is pursuing its strategy to strengthen its presence in overseas territories.

ADVANT Altana advised Albioma with a team led by partner Jean-Nicolas Soret, Eléonore Vucher-Bondet and Théodore Sabot on corporate matters, Louis des Cars, and Clément Balzamo on issues relating to urban planning and public law, Phillipe de Saint Bauzel and Alexandre Thuau-Renaudet on tax law. 

This transaction demonstrates ADVANT Altana's know-how in the renewable energy sector.

The financing of the EU's tasks must be secured in the long term and requires comprehensive budget planning. The basis of this budget planning is the so-called "Multiannual Financial Framework“, and the next one must be adopted unanimously by the Member States for the years 2028 to 2034 on a proposal from the European Commission with the consent of the European Parliament. The Commission presented its draft on July 16, 2025, and it is quite ambitious. But what exactly is the "Multiannual Financial Framework"? Which changes does it make compared to the previous funding period? What happens next?

What is the "Multiannual Financial Framework"?

Based on Art. 312 of the Treaty on the Functioning of the European Union (TFEU), the "Multiannual Financial Framework" (MFF), which is the responsibility of the European Commission, covers the EU's budget planning for at least five – usually seven – years. It determines the financial scope of the annual EU budget by setting binding ceilings. The focus is always on promoting European cooperation, particularly in terms of growth and competitiveness. Long-term budget planning enables investment projects to be aligned over several years and thus designed more efficiently. Variable elements of the MFF allow a flexible response to crises and emergencies such as natural disasters. Moreover, it enables financial resources to be deployed quickly and precisely.

In addition to the MFF, the EU also has subsidiary budgets. The most prominent example of this is NextGenerationEU (NGEU). This is a temporary recovery program that was launched in 2020 to deal with the economic and social impact of the COVID-19 pandemic. With a volume of more than EUR 800 billion, NGEU aims to finance economic recovery in the EU and promote investment.

There are also other budgets outside the traditional financial framework, such as the European Peace Facility (EFF). The facility was set up for the period 2021-2027 with a volume of EUR 5.69 billion and serves to support countries affected by military conflicts.

What are the main innovations of the MFF 2028-2034?

A – Increasing the budget and new sources of revenue

The Commission wants to significantly increase the budget. The current MFF 2021-2027 has a total volume of around EUR 1,211 billion, which corresponds to around 1.11% of the gross national income (GNI) of the EU-27. In addition, there are funds from the "Next Generation EU" reconstruction program amounting to around EUR 800 billion.

The current EU budget, including NGEU funds, therefore amounts to around EUR 285 billion per year. In comparison, the German federal budget alone is already around EUR 450 billion, i. e. almost twice as much.

The European Commission considers the current budget volume for the future MFF 2028-2034 to be insufficient, particularly regarding the need to overcome global instabilities and to finance climate protection and biodiversity. The European Commission wants to invest EUR 2,000 billion to future-proof the EU. "The next Multiannual Financial Framework is the most ambitious we have ever proposed. It is more strategic, more flexible, more transparent", says European Commission President Ursula von der Leyen. But where will this funding come from?

To keep the Member States' national contributions stable, the European Commission is trying to tap into new own resources. At present, the fulfilment of EU tasks is largely financed by contributions from the Member States, and they would rather "transfer less to Brussels" than more. On the one hand, ecological levies are proposed, i. e. revenues from the EU Emissions Trading System (ETS) and the Carbon Border Adjustment Mechanism (CBAM) are to be used permanently as own resources, with 30 % of ETS revenues flowing into the EU budget in addition to the proceeds from the CBAM. On the other hand, revenue is to be generated from the taxation of multinational corporations: With the planned taxation of corporate profits in the EU through the BEFIT (Business in Europe: Framework for Income Taxation) instrument as well as revenue from the OECD-driven Pillar One of the global minimum tax system.

B – Changes

The heart of the new MFF are the national and regional partnership plans, which shall form the basis for investments and reforms. The European Commission would like to invest EUR 865 billion just for this.

In addition, the European Commission intends to modernize the Common Agricultural Policy (CAP) and adapt it to new ecological and social requirements. A further EUR 300 billion has been earmarked as income support for farmers, which corresponds to double the amount of the agricultural reserve compared to the previous MFF.

In addition, programmes to reduce economic and territorial disparities between regions should be more efficient and customs and excise duties should be optimized.

Another important proposal is the establishment of a European Competitiveness Fund with almost EUR 410 billion. This fund bundles up to 14 previously separate programmes, including innovation, digitalization, climate protection, health and defence, into a single, thematically focused fund. The aim is to promote strategic investments in key technologies, drive forward industrial decarbonization and strengthen Europe's global competitiveness.

What criticism is there of the planned changes to the MFF 2028-2034?

The European Commission's draft has not met with a positive response everywhere. The European Parliament has already rejected the European Competitiveness Fund proposed by the European Commission as inadequate. Large funds are considered unsuitable for guaranteeing parliamentary control. It also criticizes the model of a national plan per member state ("single plan"), as is practiced with the Recovery and Resilience Facility. The European Parliament will not accept any restriction of its duty of oversight and democratic control over EU funds. Instead, it is calling for a differentiated structure with strong parliamentary control and the involvement of regional and local authorities.

Several member states also reject a significant increase in the EU budget. If this were to be accompanied by an increase in the expenditure ceiling above the current level of 1 % of GNI, which in turn is criticized by the European Parliament and the European Commission. "Frugal" states such as Germany have already spoken out against an increase in the EU budget. France has even announced its intention to cut payments to the EU budget in 2026.

Many member states are sceptical about new, mandatory own resources and additional financial burdens that go beyond management or structural reforms. Regardless of the Commission's proposals for new financing instruments, differences remain, for example regarding the integration of new thematic areas or centralized control.

How will defence be financed?

There is overwhelming consensus on increasing the defence budget. The financing of defence is based on the European Defence Fund (EDF). This is the central EU instrument for promoting research, development and joint procurement of modern defence technologies. For the current period 2021-2027, the fund has a budget of EUR 7.3 billion at its disposal. Given the current geopolitical situation, the European Commission has invested EUR 910 million in strengthening the innovative and interoperable defence industry in Europe this year. The European Commission's proposal provides for a special mechanism with a financial impact of almost EUR 400 billion to deal with serious crises. EUR 131 billion is to be invested from the Competitiveness Fund in the areas of defence and space. A further EUR 100 billion is earmarked for Ukraine's recovery and resilience. 

In addition to the EDF, the European Commission is planning a comprehensive rearmament as part of its "ReArm Europe" initiative. To this end, it plans to borrow EUR 150 billion through capital market bonds. This should enable rapid and targeted investments without placing an undue burden on national budgets. Over the next four years, around EUR 800 billion will be mobilized, a large part of which is to be covered by an increase in national defence spending by the member states of 1.5 % of GDP.

Further considerations concern the establishment of a so-called "rearmament bank", which is supported by EU member states as well as foreign partners such as the USA and the UK, to simplify and bundle financing for defence technologies. This bank would issue triple-A bonds backed by the shareholder states and thus mobilize additional funds without increasing the debt levels of the member states.

What happens next?

The proposal for the 2028-2034 MFF submitted by the European Commission on 16 July 2025 will be discussed over the next two years. The new MFF must be adopted unanimously in the Council and by simple majority in the European Parliament.

How the European Commission will manage the balancing act between future-orientated policy with new tasks and expenditure desired by the European Parliament and the savings wishes of the Member States cannot be predicted. So far, negotiations have been characterised by the paradox that every Member State wants to get more out than it pays in. Furthermore, in the EU as elsewhere, regrettably, different points are being linked together: For example, the approval of EU sanctions with commitments in favour of individual EU Member States, as in the recent case of Slovakia's delayed approval of the 18th sanctions package against Russia. In the next two years, there will certainly be tough disputes over the proposal. Besides, the MFF 2028-2034 will certainly look different from what was proposed.

Gábor Báthory
Prof. Dr. Rainer Bierwagen
Christian Hipp
Dr. Dietmar O. Reich

Sources

Proposal of the European Commission

https://commission.europa.eu/strategy-and-policy/eu-budget/long-term-eu-budget/eu-budget-2028-2034_en

Parliament's priorities for the Multiannual Financial Framework from 2028 onwards | News | European Parliament

Budget proposal "simply not enough", say MEPs | News | European Parliament

Example comments from Baden-Württemberg

https://stm.baden-wuerttemberg.de/de/service/presse/pressemitteilung/pid/vorschlag-der-eu-kommission-fuer-mehrjaehrigen-finanzrahmen 

welcome to the June issue of ADVANT Beiten's International Briefing.

Germany remains one of the world’s most attractive destinations for foreign direct investments. This reputation is well-deserved, as the country offers a stable legal environment, a highly skilled workforce, and a dynamic industrial landscape, all of which create a robust foundation for successful business ventures. In ADVANT Beiten's newly released guide "Investing in Germany" our experts provide a comprehensive overview of the legal framework for foreign investments in Germany - practical, understandable and with extensive experience in the field of foreign direct investments.

This year our Beijing office proudly celebrates its 30^th anniversary. We are delighted to share with you an insightful interview with our Beijing team of Susanne Rademacher, Dr Jenna Wang-Metzner, and Lelu Li, highlighting their dedication and three decades expertise in the field of the inbound and outbound investments in China.

In this issue we will also highlight interesting developments in the European and German legal landscape, invite you to meet us at international events, and tell you about our recent deals.

You can find the newsletter by clicking here.

Kind regards,

Dr Barbara Mayer
Prof. Dr Hans-Josef Vogel
Dr Christian von Wistinghausen
Moritz Kopp

Despite this, hydrogen remains a key technology in the eyes of the new coalition government. With the special infrastructure fund^[2] on the one hand and the prospect of an expanded framework for state aid on the other, there is indeed new impetus that gives hope.

Reason enough to take a look at the political agenda and the corresponding levers in the regulatory framework. 

What does the coalition agreement say?

The future of the hydrogen economy is negotiated centrally in the coalition agreement in no less than twenty lines (p. 34), which are a tough sell:

Pragmatism instead of dogmatism

The development of the hydrogen economy should be faster and more flexible. In addition, "all colours" of hydrogen are to be used - in other words, a technology-neutral approach is to be pursued. The previous focus on green hydrogen in particular will thus be abandoned. Moreover, the focus of the future certification system (probably for both green and low-carbon hydrogen) is on making it unbureaucratic.

Broad infrastructure expansion

With additional routes and taking into account hydrogen storage facilities, the hydrogen core network is to be supplemented by a distribution network infrastructure to ensure a connection to the industrial centres in the south and east. In addition, European and German harbours are to be integrated into and connected to the necessary infrastructure for the import of hydrogen.

Stabilise funding instruments

National and European funding programmes are still needed to develop infrastructures and domestic production capacities. The coalition agreement explicitly mentions H2Global, IPCEI projects and specific programmes for SMEs.

Further ideas for additional incentives for the demand for hydrogen can already be found on p. 6 of the coalition agreement. There, climate-neutral lead markets are outlined via the quota regime (e.g. for green steel) or levers under public procurement law.

What does the European Clean Industrial Deal make possible?

If the Commission has its way, Germany (and the other Member States) will in future have an extended framework under state aid law for the promotion of investments in hydrogen ramp-up.

The draft Clean Industrial Deal^[3] presented by the Commission in February also explicitly provides for a new aid framework (Clean Industrial State Aid Framework - CISAF^[4]). This is intended to complement the existing guidelines for state aid for environmental, climate protection and energy. As the name already suggests, the focus is on industrial policy requirements. In addition, the present draft explicitly recognises the challenge of the cumulation of different state aid vehicles and attempts to resolve this.

In addition, further impetus for the hydrogen industry is expected from Brussels. For instance, the delegated act on low-carbon hydrogen is to be adopted in 2025 to create clarity for investors. This will be accompanied by a study to assess the effectiveness of the current regulatory framework and to identify potential obstacles to the expansion of renewable hydrogen.

In the second quarter of 2025, a hydrogen mechanism is to be introduced via the European Hydrogen Bank (EHB) which will bring together buyers and suppliers and provide financing and risk mitigation instruments. A third bidding round of the EHB with a budget of up to EUR 1 billion is planned for the third quarter of 2025.

Seize opportunities - minimise risks

With the change of government acting as a catalyst, the legal framework for the hydrogen economy, including the funding landscape, is likely to change again over the next few months.

In addition to new funding vehicles, however, adjustments to existing privileges cannot be ruled out.

For instance, in its recently published discussion paper on the further development of the general grid fee system, the Federal Network Agency casts doubt on the appropriateness of the existing 20-year grid fee privilege for electrolysers.^[5]

Hence, flexible regulations are needed in the contractual design of projects that safeguard economic interests even against the backdrop of a constantly changing legal situation. 

In addition, funding law challenges must be overcome when cumulating privileges. This is because national regulations can also fall under cumulation bans beyond the subsidies approved under state aid law, e.g. as part of the IPCEI waves or the EHB tender processes. Finally, there is also a risk of reclaims if funding recipients violate public procurement law requirements when using the funding. In procurement processes, the framework set by the respective funding provider and the applicable public procurement law should therefore be observed without exception to avoid unpleasant surprises - e.g. in the context of a later audit of the utilisation of funds.

Conclusion

With the special infrastructure fund on the one hand and the short-term expansion of state aid instruments on the other, the chances of a successful market ramp-up in Germany are better than they have been for a long time.

In addition, Katherina Reiche is a proven expert at the head of the BMWE who credibly stands in favour of consolidating the legal framework. The speed at which the requirements for new projects and those already being realised are likely to remain high.

Authors: Sebastian Berg and Max Stanko

Experts involved: Julian Gruß and Johannes Voß-Lünemann

^[1] Cf. BDEW, Strombezugskriterien Delegierter Rechtsakt für RFNBO-konformen Wasserstoff, with clear criticism of the current design of the additionality and temporal correlation criteria, available at: Strombezugskriterien Delegierter Rechtsakt für RFNBO-konformen Wasserstoff | BDEW

^[2]In this respect, the DVGW is calling for a further 50 billion from the special infrastructure fund to finally boost the market ramp-up, DVGW e.V.: 2025-04-23 - Sondervermoegen.

^[3]See also: EU-Kommission stellt den Action Plan for Affordable Energy als Teil des Clean Industrial Deals vor | ADVANT Beiten

^[4] See draft version under 45b532ce-53fb-4907-975c-79edaa31a166_en.

^[5] BNetzA, Bundesnetzagentur - Presse - Bundesnetzagentur veröffentlicht Diskussionspapier zur Bildung der Stromnetzentgelte.

With its SolarMe electricity brand, Solarimo offers tenant electricity solutions for the housing industry. With this transaction, 300 photovoltaic systems with an installed capacity totalling 10.3 megawatts are to be transferred to Einhundert's operations by the end of the year. The systems are expected to supply more than 10,000 tenants across Germany with locally generated solar power. This is expected to save around 4,000 tonnes of CO2 per year.

ENGIE Deutschland GmbH is committed to accelerating the transition to a carbon-neutral economy. In Germany, the company plans, builds, operates and markets wind, photovoltaic and hydropower plants as well as pump storage and battery storage systems. Engie trades in electricity and gas and supplies end customers with energy.

The transaction was led by Dr Barbara Mayer, Christian Burmeister and Peter Meisenbacher at ADVANT Beiten. 

Einhundert Energie GmbH has been supporting real estate companies in the electrification and decarbonisation of their building portfolios since 2017. The Cologne-based company enables housing companies and their tenants to participate in the energy transition. The aim is to use 100 per cent CO2-neutral energy from local PV systems.

Consultant Solarimo:

ADVANT Beiten: Dr Barbara Mayer (Corporate/M&A, Freiburg), Christian Burmeister (Corporate/M&A, Freiburg/Berlin), Peter Meisenbacher (Public Sector/Energy, Freiburg/Berlin, all lead partners), Dr Erik Schmid, Alexander Gräßel (Labour Law, Munich/Freiburg).

Consutant Einhundert Energie:

Noerr: Dr Christoph Thiermann, Dr Christian Haagen (Munich/London)

Public Relations

Frauke Reuther
Manager Kommunikation
ADVANT Beiten
+49 (69) 75 60 95 - 570
frauke.reuther@advant-beiten.com

Dr Barbara Mayer
Rechtsanwältin
ADVANT Beiten
+49 (761) 15 09 84 - 14
Barbara.Mayer@advant-beiten.com

Christian Burmeister
Rechtsanwalt
+49 (761) 15 09 84 - 18
Christian.Burmeister@advant-beiten.com

The acquired portfolio consists of three ready-to-build solar projects. The first project is located in Saarland, the second is an innovative Agri-PV project in Mecklenburg-Western Pomerania and finally another Agri-PV initiative in Lower Saxony. These projects are expected to be completed between mid and late 2025.

The ADVANT Beiten team, led by Dr. Christof Aha, regularly advises Trinasolar.

Trinasolar ISBU is the project development arm of Trinasolar and specializes in the development, engineering, procurement, construction, operation and maintenance as well as asset management of solar and battery storage projects worldwide.

Emeren Group is a global developer and operator of solar projects. The shares of Emeren Group Ltd. are listed on the NYSE.

Trinasolar France and Emerem Group have already worked together successfully in the past. With this strategic transaction, Trinasolar strengthens its commitment to expanding renewable energy solutions and promoting sustainable developments across Europe.

Advisor Trinasolar:
ADVANT Beiten: Dr Christof Aha (lead), Mark Thönißen, Felix Busold (all Corporate/M&A), Leopold Linden (Real Estate, all Frankfurt), Katrin Lüdtke (Public Law, Munich).
Inhouse Trinasolar: Esther Muñoz Contreras (Rome)

Advisor Emerem Group:
BNK: Dr. Florian Brahms, Désirée Oberpichler (both Hamburg)
Inhouse Emerem Group: Manuel Ales, Teresa Cera Mora (both Madrid)

Press contact
Frauke Reuther
Communications Manager
ADVANT Beiten
+49 (69) 75 60 95 - 570
frauke.reuther@advant-beiten.com

One element of this package of measures is the Action Plan for Affordable Energy. It presents a roadmap for affordable and secure energy supply. 

The following text gives you an overview of the key points of this roadmap.

I. The EU action plans

Energy prices in the EU have risen dramatically in recent years, affecting households, companies and industry alike. Energy-intensive industries in particular are facing rising costs that jeopardise their competitiveness on the global market. At the same time, geopolitical uncertainties and dependence on fossil fuel imports are exacerbating the situation.

At the end of January 2025, the European Commission already described and announced measures in its Competitiveness Compass for the EU, based on the Draghi Report, that are intended to accelerate the transformation of the EU and increase its competitiveness. 

The Green Industrial Deal has now been published as part of this Compass. In this context, the EU Commission presents, among other things, the Action Plan for Affordable Energy.

The aim of this Plan is to reduce energy costs in the short term, accelerate structural reforms and create a stable, climate-friendly and competitive energy system within the EU in the long term.

II. High energy costs in the EU

The Commission lists several factors that are responsible for the high energy costs. On the one hand, it mentions the heavy dependence on imported fossil fuels, especially gas. High price fluctuations on the global markets and geopolitical tensions are inflating costs. On the other hand, the report identifies a disadvantage in the still inadequate integration of the European electricity grid, which leads to grid bottlenecks and inefficiencies and therefore to higher costs. High taxes, grid fees and levies in the individual Member States are also cited as major factors causing high and rising energy prices.

III. The four pillars of the Action Plan

In order to reduce these high energy costs quickly and systematically and to make the energy system fit for the future, the Action Plan presents four pillars containing a total of eight actions: Lowering energy costs (Pillar 1), completing the Energy Union (Pillar 2), attracting investments (Pillar 3) and being ready for potential energy crises (Pillar 4).

Pillar 1: Lowering energy costs

In Pillar 1, the EU Commission defines four actions to lower energy costs.

Action 1: Make electricity bills more affordable

As a first step, network charges will be reduced and taxes and levies lowered. The Commission intends to introduce new pricing structures for this purpose, designed specifically to promote flexible grid use and grid stability. The Commission also wants to issue recommendations to the Member States on reducing taxes and levies, with the costs to be shifted to the national budgets. In addition, switching energy suppliers will be made easier for consumers, and energy communities will be promoted.

Action 2: Bring down the cost of electricity supply

Besides the above, the Commission plans to develop legal guidelines for power purchase agreements (PPAs) and contracts for difference (CfDs) to promote more favourable procurement models and the integration of renewable energies also for those consumers who have so far had little access to this type of electricity supply. Regulatory obstacles will be removed by the Member States and certain instruments will be introduced to minimise risk. 

The Commission also intends to make legislative proposals to further shorten authorisation procedures for grids, storage and renewable energies. Member States will be supported in their efforts to improve the human and financial resources of the authorisation authorities. This should reduce approval periods to less than six months for simpler projects, such as repowering projects in acceleration areas.

The presentation of a European Grid Package, which will build on the Network Action Plan already in place since 2023, is also aimed at accelerating the modernisation and digitalisation of the networks in Europe. System flexibility is going to be increased through the further expansion of storage capacity and also through demand response. To this end, the Member States should implement the EU regulations on market access more quickly and offer better incentives to make flexibility more attractive for the individual stakeholders.

Action 3: Ensure well-functioning gas markets

The competitiveness of the gas markets will be improved through fair prices. It is planned that a Gas Market Task Force will thoroughly scrutinise the market and take steps to ensure the proper functioning of the market and prevent market distortions. A broad stakeholder consultation will be launched in the areas of regulatory oversight, alignment and strengthening of energy and financial market rules, reduction of administrative burden for companies trading in energy financial markets and the introduction of a common harmonised database. The work of the task force is expected to be completed by the 4th quarter of 2025 with the delivery of a recommendation.

Action 4: Energy efficiency - delivering energy savings

Another aspect of lowering energy costs is to reduce energy consumption, i.e. improve energy efficiency. Access to energy efficiency services will be facilitated and financial incentives increased, both for companies and consumers. Especially the latter will be offered easier access to energy-efficient products and products with a longer service life. To this end, labelling and ecodesign regulations will be adapted. 

Pillar 2: CompletIng the Energy Union

The Commission addresses the completion of the Energy Union in Pillar 2 of the Action Plan - which is also Action 5. Meeting this goal requires long-term structural measures. The Commission proposes, among other things, the introduction of an Energy Union Task Force for improved coordination between the Member States, the revision of the existing Energy Union Governance Regulations and the introduction of a Heating and Cooling Strategy. An investment strategy for clean energy and a strategic roadmap for digitalisation and AI in the energy sector will also be presented.

Pillar 3: Attracting investments

In Pillar 3, the Commission deals with the financing of the energy transition. Securing a stable and affordable energy supply for European industry in the long term will be made easier.

In Action 6, the Action Plan therefore provides for the creation of a favourable investment climate through a tripartite contract for affordable energy between energy producers, public sector and industry. The European Investment Bank (EIB), the Commission and the Member States are expected to support the parties involved. The aim is to provide predictability and scalability. 

Pillar 4: Being ready for potential energy crises 

Pillar 4 provides the Member States with appropriate instruments to enhance resilience of the energy market during future energy crises and to strengthen security of supply.

In Action 7, the Commission therefore announces a proposal to revise the current EU legal framework for the security of energy supply. The proposal will help to stabilise prices by drawing on the experience of the current energy crisis. This is aimed at ensuring better availability of energy at all times.

Action 8 guides the Member States on incentives through an appropriate remuneration system to reduce demand at peak times. Grid operators are encouraged to implement measures to reduce energy consumption at certain times. This is intended to keep the energy bill down and to reduce price volatility. Action 8 aims at stabilising the energy market and improving price control. In cases where a grid bottleneck or overload severely impedes the flow of energy, close cooperation between the transmission system operators (TSOs) and the national authorities will continue. Overall, cross-border electricity trading is to be maximised to mitigate local price peaks and guarantee the supply of energy.

IV. Conclusion and outlook

The measures presented in the Action Plan for Affordable Energy are numerous and range from specific adjustments to existing regulations all the way to reports by task forces yet to be established based on which specific measures will have to be developed. The Action Plan’s aim to reduce energy prices in the EU and thus strengthen competitiveness is certainly equally important and valid for all Member States, consumers and industry. It remains to be seen exactly which measures will be implemented and how they can and must be integrated into the German legal framework. The timelines for the implementation of the measures listed in the Action Plan range from ‘immediately‘, through the first calendar quarter of 2025, to the beginning of 2026. 

We will monitor the developments and the impact on individual market participants, analyse them and keep you informed.

Peter Meisenbacher
Dr Malaika Ahlers LL.M.

Sebastian Berg, Anton Buro und Dr Florian Böhm from our Energy team will also be happy to answer any questions you may have on energy law-related issues.