24.06.2026 – “The law eliminates or softens numerous thresholds, deadlines, and additional requirements that the previous government had introduced. This provides significant relief to affected companies, especially the SMEs already severely burdened by bureaucracy. Nevertheless, the goal of rigorously aligning the Energy Efficiency Act with EU directives has not been achieved. The draft still contains excessive requirements, growth-inhibiting regulations, and impractical provisions. These should be further reduced in the upcoming procedure.

In relation to the national savings targets introduced by the previous government, it is positive that reference is now made solely to the targets already reported in the National Energy and Climate Plan. This is a step in the right direction. However, it would have been consistent to completely refrain from anchoring such targets in the law. Statutory binding energy saving targets could have significantly hampered economic development. A DIHK calculation indicates: If the previously achieved efficiency increase of 1.7 percent per year is continued and the consumption target of 1,867 TWh in 2030 is strictly adhered to, this would result in an approximately 9 percent lower economic output by 2030 compared to 2024.

Unfortunately, the draft misses the chance to consolidate the relevant efficiency regulations from the Energy Services Act and the Energy Efficiency Act into a coherent legal framework. This creates uncertainty for businesses and unnecessary complexity, such as unclear definitions and missing explanations, for example, regarding the concept of a company. Transition regulations are also important to avoid fines during the shift from old to new thresholds and deadlines.

The Bundestag should now consistently pursue the path of harmonisation and de-bureaucratisation and streamline the draft law further in the parliamentary procedure. Significant simplifications, especially through the consolidation and harmonisation of data collection, reporting, and notification obligations, are possible. Moreover, the Federal Government should advocate for a simplified, growth-promoting, and practical legal framework at the European level.”