Cost efficiency yes, but not like this: why the EEG 2027 draft structurally disadvantages agrivoltaics

5 min read · Updat­ed on 22 Octo­ber 2026

As an agri­v­oltaics devel­op­er in Ger­many, we see a struc­tur­al flaw in the cur­rent work­ing draft of the EEG 2027 (as of late April 2026) that must be cor­rect­ed: abol­ish­ing every form of com­pen­sa­tion for spe­cial solar instal­la­tions, in par­tic­u­lar agri­v­oltaics, does not cre­ate a lev­el play­ing field; it dis­torts it. With this paper, Ylek­tra presents its offi­cial posi­tion.

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Our basic conviction: yes to the market, but on fair terms

Ylek­tra devel­ops, builds and oper­ates agri­v­olta­ic projects in Ger­many. We know the reg­u­la­to­ry, tech­ni­cal and eco­nom­ic require­ments of this tech­nol­o­gy from our day-to-day project work. And that is exact­ly why we are tak­ing a clear posi­tion on the cur­rent work­ing draft of the EEG 2027.

First, the most impor­tant point: we are not oppo­nents of mar­ket-based ten­ders. Ylek­tra already offers agri­v­olta­ic projects in com­pe­ti­tion with con­ven­tion­al ground-mount­ed sys­tems today, and does so suc­cess­ful­ly. We express­ly sup­port cost-effi­cient elec­tric­i­ty gen­er­a­tion as the guid­ing prin­ci­ple of the EEG amend­ment.

We are not ask­ing for spe­cial treat­ment, but for a reg­u­la­to­ry frame­work that reflects real­i­ty.

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What the current draft provides for, and why that is a problem

The work­ing draft (as of 21 April 2026) pro­vides for the exist­ing agri­v­oltaics sub-seg­ment under Sec­tion 37d EEG 2023 to be delet­ed with­out replace­ment. Agri­v­olta­ic sys­tems over 1 MW would in future com­pete direct­ly with con­ven­tion­al ground-mount­ed sys­tems in gen­er­al seg­ment 1, at the same max­i­mum val­ue of no more than 5.9 ct/kWh. For sys­tems below 1 MW, the pre­vi­ous pre­mi­um is dropped, and the applic­a­ble val­ue is low­ered to a uni­form 6.2 ct/kWh.

At first glance, this sounds like mar­ket neu­tral­i­ty. It is the oppo­site.

Any­one build­ing an agri­v­olta­ic sys­tem bears costs that a con­ven­tion­al ground-mount­ed sys­tem does not: a more com­plex design for clear­ance height and span, a cul­ti­va­tion con­cept, ongo­ing proof of agri­cul­tur­al use, and doc­u­men­ta­tion in line with DIN SPEC. These costs are not option­al extras; they are the legal con­di­tion for the land being used for agri­cul­ture at the same time. Delet­ing the com­pen­sa­tion for them with­out replace­ment is not a mar­ket clean-up. It is a dis­tor­tion of com­pe­ti­tion through a state-imposed asym­me­try.

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The coalition agreement sets a clear direction

The coali­tion agree­ment between the CDU/CSU and the SPD of April 2025 is unam­bigu­ous. In the chap­ter on solar ener­gy it states:

“We pay atten­tion to con­serv­ing land and want to make it eas­i­er to use land for more than one pur­pose, such as car park, agri and float­ing PV.”

Coali­tion agree­ment CDU/CSU · SPD, April 2025 (our trans­la­tion)

Delet­ing all agri­v­oltaics-spe­cif­ic sup­port instru­ments is not a way of facil­i­tat­ing dual use. It is its reg­u­la­to­ry dis­man­tling. We expect the Fed­er­al Min­istry for Eco­nom­ic Affairs to resolve this con­tra­dic­tion in the fur­ther leg­isla­tive process.

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Our specific demands

Systems over 1 MW: a technology bonus in the shared segment

We are not demand­ing the return of a sep­a­rate agri­v­oltaics seg­ment. Com­pe­ti­tion in the shared seg­ment 1 is appro­pri­ate and in line with the mar­ket, and agri­v­oltaics must face it.

What we are ask­ing for: spe­cial solar instal­la­tions bear reg­u­la­to­ry addi­tion­al costs that do not arise to the same extent for con­ven­tion­al ground-mount­ed sys­tems. A small tech­nol­o­gy bonus with­in the shared seg­ment 1, anal­o­gous to today’s sup­port, is the appro­pri­ate min­i­mum instru­ment to off­set this asym­me­try with­out remov­ing com­pe­ti­tion between projects.

The ten­der results of recent years show that, with today’s pre­mi­um of just 0.5 ct/kWh, agri­v­oltaics can bid com­pet­i­tive­ly and win awards. That is not mar­ket fail­ure; it is the mar­ket cor­rect­ly reflect­ing the actu­al costs of dif­fer­ent tech­nolo­gies.

Systems below 1 MW: a degressive premium instead of a uniform tariff

For agri­v­olta­ic sys­tems below 1 MW that are exempt from ten­ders, a clear­ly defined pre­mi­um on the applic­a­ble val­ue of 6.2 ct/kWh should be intro­duced, reflect­ing at least the reg­u­la­to­ry addi­tion­al costs of dual use com­pared with a con­ven­tion­al sys­tem of the same capac­i­ty class.

Impor­tant­ly, this pre­mi­um should be degres­sive in order to pro­mote effi­cien­cy gains and avoid wind­fall effects. This is a pro-mar­ket solu­tion: it pro­vides short-term com­pen­sa­tion with­out cre­at­ing per­ma­nent depen­dence on sub­si­dies.

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Why this matters for the energy transition

Agri­v­oltaics is not a niche tech­nol­o­gy. It is the answer to one of the cen­tral con­flicts of the ener­gy tran­si­tion: com­pe­ti­tion for land between agri­cul­ture and pho­to­voltaics. An agri­v­olta­ic sys­tem resolves this con­flict: it gen­er­ates elec­tric­i­ty while main­tain­ing agri­cul­tur­al pro­duc­tion on the land.

This social func­tion has its (small) price. Any­one who makes this price invis­i­ble in reg­u­la­tion and then has the tech­nol­o­gy com­pete on the same terms as cheap­er con­ven­tion­al ground-mount­ed sys­tems is, in effect, decid­ing against agri­v­oltaics, con­trary to the coali­tion agree­ment and con­trary to the inter­ests of farm­ers, munic­i­pal­i­ties and an ener­gy tran­si­tion that peo­ple can accept.

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Our appeal

The leg­isla­tive process for the EEG 2027 is still open. Inter-min­is­te­r­i­al coor­di­na­tion, par­lia­men­tary delib­er­a­tion and the Bun­desrat pro­ce­dure offer ample oppor­tu­ni­ty to cor­rect the tech­ni­cal weak­ness­es of the draft.

We expect the Fed­er­al Min­istry for Eco­nom­ic Affairs to use the com­mit­ments of the coali­tion agree­ment as its yard­stick. Make agri­v­oltaics eas­i­er, not through pro­tect­ed spaces, but through fair con­di­tions of com­pe­ti­tion.

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Frequently asked questions (FAQ)

What is Ylektra calling for on agrivoltaics in the EEG 2027?

For agri­v­olta­ic sys­tems over 1 MW that must take part in ten­ders, Ylek­tra calls for a small tech­nol­o­gy bonus with­in the shared ground-mount­ed seg­ment, not a sep­a­rate sub-seg­ment. For sys­tems below 1 MW, Ylek­tra calls for a degres­sive pre­mi­um on the applic­a­ble val­ue of 6.2 ct/kWh that reflects the reg­u­la­to­ry addi­tion­al costs of dual use.

Why is deleting the agrivoltaics sub-segment entirely problematic?

Agri­v­olta­ic sys­tems bear reg­u­la­to­ry addi­tion­al costs that con­ven­tion­al ground-mount­ed sys­tems do not incur: a more com­plex design, a cul­ti­va­tion con­cept, ongo­ing proof of agri­cul­tur­al use and doc­u­men­ta­tion in line with DIN SPEC. With­out com­pen­sa­tion, agri­v­olta­ic sys­tems com­pete at high­er cost for the same max­i­mum val­ue, a state-imposed asym­me­try in com­pe­ti­tion.

Does the EEG 2027 draft contradict the coalition agreement?

Yes. The coali­tion agree­ment between the CDU/CSU and the SPD of April 2025 express­ly com­mits the fed­er­al gov­ern­ment to mak­ing dual-use options such as agri­v­oltaics eas­i­er. Delet­ing all agri­v­oltaics-spe­cif­ic sup­port instru­ments is the oppo­site.

What is Ylektra and why is Ylektra relevant in this debate?

Ylek­tra GmbH is a project devel­op­er spe­cial­is­ing in agri­v­oltaics. The com­pa­ny devel­ops, builds and oper­ates agri­v­olta­ic projects across Ger­many and is direct­ly affect­ed by the reg­u­la­to­ry changes of the EEG 2027. Ylek­tra brings many years of prac­ti­cal project devel­op­ment expe­ri­ence to the ener­gy pol­i­cy debate.

Has the EEG 2027 draft already been adopted?

No. The doc­u­ment is a work­ing draft of the Fed­er­al Min­istry for Eco­nom­ic Affairs (as of 21 April 2026), which is in inter-min­is­te­r­i­al coor­di­na­tion. In the his­to­ry of the EEG, no draft has ever entered into force unchanged. Ylek­tra is active­ly fol­low­ing the leg­isla­tive process.

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Ylek­tra GmbH spe­cialis­es in the devel­op­ment and real­i­sa­tion of agri­v­olta­ic projects with bat­tery stor­age. The com­pa­ny devel­ops, builds and oper­ates agri­v­olta­ic projects across Ger­many, from land acqui­si­tion and per­mit­ting to grid con­nec­tion and oper­a­tion.