Multiple banking institutions have criticized the government’s planned energy laws in a letter addressed to Federal Economic Minister Katharina Reiche (CDU) and Federal Network Agency Head Klaus Müller. This information was reported by Politico, citing the letter sent on Monday. The letter emphasizes that, in addition to solid planning, the wide availability of funding resources is crucial for the success of the energy transition due to the high capital intensity of the projects. The signatories include the Financing Advisory Board of the Federal Wind Energy Association, which features representatives from Commerzbank, Deutsche Kreditbank, GLS, LBBW, and Hypovereinsbank, alongside various regional savings banks and Volksbanken.
The authors specifically criticize that the new energy laws-such as the planned EEG amendment and the proposed grid package-could introduce additional and unquantifiable cost and revenue risks. They warn that the debt levels, loan terms, and risk costs for onshore projects might deteriorate, and the requirements for equity capital could increase.
They hold several specific measures from the government’s proposals responsible for this instability. One concern is the so-called operational limit (“Wirkleistungsbegrenzung”), which limits the maximum amount of energy a facility can feed into the grid. According to the letter, this applies not only to future projects but also to enterprises that already have permits and subsidies from the tender process, meaning they already have a fixed basis for calculation. Furthermore, projects that have already received or valued credit commitments but are not scheduled to start operation by 2026 could also be impacted, thus creating uncertainty for both developers and financiers.
Additionally, the government’s planned Redispatch reserve-which mandates the curtailment (forced shutdown) of solar and wind facilities to prevent grid bottlenecks-is described as a “significant interference with economic viability.”
