Germany’s merchant renewables are new, not old

The expected story, and why it is wrong

The obvious hypothesis about German renewables leaving subsidy is ageing. EEG support runs for 20 years, so the 2000s build-out should now be rolling off and into the merchant market. That is the story the trade press has told about ausgeförderte Anlagen for several years.

The settlement data does not support it.

Merchant assets are nine years newer than supported ones. Only 47 of 744 (6%) were commissioned in 2005 or earlier — the cohort whose 20-year entitlement has actually expired.

The assets selling without EEG support in Germany are overwhelmingly new plants that never took it, not old plants that ran out.

What that looks like

The largest merchant assets are recent utility-scale solar.

By technology, merchant capacity is 664 solar assets (4,314 MW) and 80 wind assets (1,585 MW).

Why it matters for anyone buying these assets

• –Subsidy expiry is the wrong lens. Screening German renewables by "years until support ends" misses the 5,899 MW that never had support to lose. Their revenue risk is a PPA counterparty and a capture price, not a cliff-edge date.
• –Merchant exposure is observable per asset, not just modelled. Diligence normally infers scheme participation from commissioning year plus statutory tenor, because per-asset scheme data is assumed unavailable. For Germany it is in the settlement record.
• –The 266 partly-merchant assets are the interesting middle. Mixed volume in a single year usually means a transition — worth looking at individually rather than bucketing.

Method

Two public sources, joined.

• –MaStR (Marktstammdatenregister), the German national energy register — asset identity, operator, capacity, location. Licence DL-DE-BY-2.0.
• –EEG-Bewegungsdaten — per-installation settlement movement data published by the four German TSOs under §51(1) No. 2 EnFG, annually on 15 September.

The join key is EEG_Mastr_Nr, present on 99.34% of settlement rows and matching MaStR’s EegMaStRNummer directly. Those units are matched to plant-level asset records by capacity-constrained spatial matching, and only high-confidence matches are used.

"Merchant" here means *more than 90% of the asset’s settled 2024 volume fell under Veräußerungsform 5 (Sonstiges) — volume settled outside the EEG’s support forms. Across all four TSOs that category settles at €5.56/MWh, against €58.31/MWh* for the market premium. That gap is what "no support" looks like in the payment column.

Limits — read these before quoting the number

• –One year. This is the 2024 settlement, published September 2025. A snapshot, not a trend. An asset can carry mixed volume in a transition year, which is why "partly merchant" is a separate bucket rather than rounded away.
• –Veräußerungsform 5 is an interpretation. The category is Sonstiges. Reading it as unsupported direct marketing is supported by the €5.56/MWh settlement rate, not by an explicit label in the data.
• –Coverage is partial. 5,942 German assets carry measured settlement, out of roughly 10,800 German assets tracked. The figures describe the matched set, not the country.
• –474 of the 5,942 are apportioned. Where the asset register splits one site into phases sharing a single registry unit, volume is divided by nameplate. Estimates at asset level, exact in aggregate.
• –This is settled volume, not revenue. For plants on a market premium the EEG payment is a top-up over their own market sales, so it cannot be read as turnover.

Reproducing it

node scripts/mastr/ingest.mjs              # MaStR wind/thermal/hydro/biomass
node scripts/mastr/ingest.mjs --solar      # MaStR solar
node scripts/eeg/ingest.mjs                # EEG settlement, all four TSOs
node scripts/mastr/match-to-gem.mjs --write
node scripts/eeg/join-to-assets.mjs --write