Tenant electricity

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Tenant electricity

The term tenant electricity describes electrical energy that is generated in decentralized power generation plants and supplied directly to tenants in apartment buildings or commercial buildings. The energy does not pass through the public electricity grid on its way from the producer to the consumer.

The tenant electricity model is usually a combination of locally generated electricity and electricity supplied from the grid. The locally generated and marketed electricity is referred to analogously as direct electricity. The tenant electricity user is also supplied with electricity from the grid, known as grid electricity, by its supplier. From the customer’s perspective, the electricity from the grid required in addition to the full supply is known as residual electricity. The supplier of the residual electricity can either be the provider of the tenant electricity or another external supplier.

Economic Potential

In the tenant electricity model, the system operator and the tenant do not pay for the locally generated electricity:

  • Grid usage fees
  • Concession fee
  • Combined Heat and Power (CHP) surcharge
  • § 19 StromNEV levy
  • AbLaV levy
  • Offshore levy

Additionally, the operator’s self-consumption, according to § 61 EEG 2017, may be exempt from or reduced to 40 percent of the EEG levy. Moreover, the system operator typically benefits from electricity tax exemption according to § 9 StromStG. However, when tenants directly consume the electricity, they must pay the full EEG levy. Nevertheless, tenants may also benefit from electricity tax exemption. The cost advantages of the Mieterstrom model are summarized in the following figure.

The economic potential of Mieterstrom models with PV systems can be further increased through the subsidy for tenant electricity according to § 21 EEG 2017. This new subsidy, also called Mieterstromzuschlag, is intended to compensate for the EEG levy when directly supplying tenants. The amount of the Mieterstromzuschlag is calculated according to § 23b EEG 2017 from the feed-in tariff for the PV system minus 8.5 ct/kWh.

What We Offer

acteno energy supports you in implementing your private or commercial tenant electricity model. As an independent metering point operator, we can provide the following services for your tenant electricity concept:

  1. Development of an individual metering concept
  2. Consideration of the site-specific system configuration and individual preferences
  3. Inclusion of legal advice and auditing as needed
  4. Coordination with grid operators, external suppliers, and auditors
  5. Installation of metering systems and integration into local control systems if required
  6. Implementation of the developed metering concept including market communication within the scope of metering point operation
  7. Visualization of collected metering data in our customer portal
  8. Fulfillment of reporting obligations in the context of electricity supply
  9. Support with invoice generation 



Legal framework

Tenant electricity models must comply with regulations from various laws and ordinances. Below you will find the most important regulations (not exhaustive).

EnWG and general framework conditions
EnWG and general framework conditions

Providers of tenant electricity are energy supply companies under the Energy Industry Act. They are therefore subject to the regulations defined for energy supply companies in the EnWG.

In the context of tenant electricity models, however, supply generally only takes place within a so-called customer facility in accordance with Section 3 No. 24a EnWG. This is advantageous because as long as a supplier only supplies end consumers within a customer facility, various simplifications apply.

The legal requirements for the contractual structure of electricity supply to household customers – for example with regard to liability, termination or price adjustments and invoicing – can be found in Sections 40 to 42 EnWG. In addition, the provisions of general civil law and in particular the requirements for general terms and conditions (GTC) must be observed when drafting electricity supply contracts.


Funding under the Renewable Energy Sources Act (EEG) is only available for the portion of electricity in tenant electricity models that is not consumed on-site but rather fed into the general supply grid (so-called surplus feed-in), with the exception of certain existing installations.

According to the EEG, system operators must adhere to the following regulations regarding funding:

  • Notification obligation to the Federal Network Agency (BNetzA) as part of the plant register (§ 6 EEG 2017)
  • Provision of technical equipment (§ 9 EEG 2017)
  • Notification obligations to the grid operator (§§ 70, 71 EEG 2017)

Furthermore, the provider of tenant electricity becomes an electricity supply company under § 3 No. 20 EEG 2017 due to the electricity supply to end consumers. The following requirements apply to the supply of electricity within the framework of tenant electricity models:

  • Notification and publication obligations to the transmission system operator (§ 74 EEG 2017) and the Federal Network Agency (§ 76 EEG 2017)
  • Regulations on electricity labeling (§ 78 EEG 2017)
  • Obligation to pay the full EEG surcharge (§ 60 EEG 2017)

Auctions: Since the EEG 2017, all PV systems with an installed capacity over 750 kW are required to participate in auctions. Funding for surplus electricity is only available if the respective system has successfully bid for a funding entitlement in an auction. Smaller installations below 750 kW installed capacity are not subject to the obligation to participate in auctions.


The electricity tax law also imposes various requirements on tenant electricity projects. The provider of tenant electricity is classified as a supplier within the meaning of § 2 No. 1 StromStG (Electricity Tax Act).

According to § 4 (1) StromStG, suppliers generally require a written permit under electricity tax law, which must be applied for at the locally competent main customs office.

Furthermore, suppliers are subject to various documentation and reporting obligations under the Electricity Tax Implementation Ordinance.


The MsbG (Metering Point Operation Act) provides for a gradually escalating obligation to install smart metering systems from 2017 onwards, “as far as technically possible and economically reasonable,” which will have a significant impact on tenant electricity models. Initially, the obligation to install smart meters applies to final consumers with an annual consumption exceeding 10,000 kWh (from 2017) or 6,000 kWh (from 2020), as well as from 2017 to operators of renewable energy systems with a capacity exceeding 7 kW (including existing systems). Statutorily staggered price caps apply in this regard.

Additionally, consumers with lower annual consumption and smaller renewable energy systems (1 to 7 kW installed capacity) may optionally have smart meters installed by the responsible metering point operator from 2020 (consumers) or 2018 (renewable energy systems) at their own cost. Furthermore, from January 1, 2021, the connection holder can also decide, with effect for all connection users, to equip the premises with smart metering systems.

REMIT Regulation
REMIT Regulation

Furthermore, Mieterstrom projects may be subject to obligations under Regulation (EU) No 1227/2011 on wholesale energy market integrity and transparency (REMIT). The REMIT regulation includes extensive reporting, registration, and disclosure requirements for various market participants.

This could affect the Mieterstrom provider if they are considered an energy trader under the regulation— for instance, if, in addition to their own electricity generation, they also procure residual electricity from the general grid and supply it to the tenants.

Reference: BSW (2016), Geschäftsmodelle mit PV-Mieterstrom