Dolivo Partners
Analysis · 15 September 2026

Transmission or distribution grid?

The maturity procedure applies only to connections to the transmission grid. A data centre of 20 to 50 megawatts usually connects to a distribution operator's 110 kV grid. It therefore falls outside the procedure. That does not put it beyond the procedure's reach.

The simple reading goes like this: connect to the distribution grid and you escape the new ranking by project maturity, because first come, first served still applies there. That is only half true, and the wrong half is expensive. A site on the distribution grid joins the wait whenever its grid operator applies to the transmission operator for capacity. It is then just one item in that operator's application, with no right to apply on its own behalf. The evidence follows, ordered by evidence grade.

01 · Voltage level

Which voltage level a site needs

A connection to the 110 kV high-voltage grid is usually needed from about 5 to 10 megawatts. Only very large projects, from about 100 megawatts, need a 380 kV connection. Vendor figure, lowest evidence grade

The 110 kV level can carry more than the rule of thumb suggests. Schwarz Digits runs a data centre with 200 megawatts of connected load directly on the 110 kV grid. Trade press

A site of 20 to 50 megawatts therefore belongs firmly at 110 kV and is a long way from 380 kV. The threshold depends on the strength of the local grid and is no national rule. The exact figure does not change the conclusion. Our own inference

02 · Scope

What the procedure covers: TransnetBW's account

According to TransnetBW, the procedure applies to battery storage, final consumers and the ad hoc capacity needs that distribution operators bring to the transmission grid. It covers only connections to the transmission grid. Distribution grids are outside its scope. The first round began on 1 April 2026. The forms give deadlines up to 16 June 2026. Primary source checked

A transmission operator thus confirms what the joint concept of all four transmission operators already implied. The procedure applies only to the extra-high-voltage grid, and the distribution operators have not adopted it.

03 · The catch

Three consequences of the ad hoc clause

The clause on distribution operators' needs is the sentence a quick reader misses. Three things follow from it. Our own inferences

01

The bottleneck only moves

If a distribution operator has no spare capacity left at the substation, it has to request it from the transmission operator. That request falls explicitly under the procedure. The site's capacity then depends on an application ranked by project maturity. Only the applicant is different.

02

The site loses its levers where it needs them most

In its own application to the transmission operator, a project can improve its ranking through its own efforts: securing land, advancing the permit, ordering transformers and switchgear. Inside a distribution operator's bundled request, it has none of these levers and cannot score. What remains is the relationship with that grid operator.

03

The screening question has a second half

The first half is: “Transmission or distribution grid?” The second is: “Does this distribution operator have spare capacity at this substation today, or is it waiting in the queue itself?” The second half appears on no published map. It is answered in conversation with the grid operator.

04 · What is not published

What grid operators do not publish

As of the end of the third quarter of 2025, the four transmission operators report a total of 717 connection applications for about 270 gigawatts. Of these, 545 applications and 211 gigawatts are for battery storage. Press release, Feb. 2026

No figure is published for individual control areas. TransnetBW's procedure page gives neither the number of applications nor the capacity available. Ranking takes place within a control area. So the number that decides the competition at a site is exactly the one no grid operator discloses. Anyone who claims a given control area has fewer applicants is claiming something that cannot currently be shown. Our own inference

One legal ambiguity remains. Section 3 EnWG defines transmission as transport over the extra-high-voltage and high-voltage interconnected grid. On its wording, that includes 110 kilovolts. The procedure and the transmission operators' documents, by contrast, draw the line at extra-high voltage. As a practical test, we use who operates the grid the site connects to. A lawyer should review this before any contract relies on it.

More on the procedure: The maturity procedure →

Sources

Where the statements come from

  • Scope, distribution operators' ad hoc needs, start of the first round and deadlines: TransnetBW, procedure page “Reifegradverfahren” (2026). Primary source.
  • 717 applications, about 270 gigawatts, of which 545 applications and 211 gigawatts are battery storage, as of the end of the third quarter of 2025: 50Hertz, Amprion, TenneT and TransnetBW, joint press release of 5 February 2026. Primary source. A secondary source dates the figure to the fourth quarter of 2025; the press release itself is authoritative.
  • 200 megawatts from the 110 kV grid at Schwarz Digits: stadt+werk (2026). Trade press.
  • Voltage levels by connected load, 5 to 10 megawatts and about 100 megawatts: FS CID (2026). Vendor figure, the lowest evidence grade used here; the figure varies with the local grid.
  • Not on this page: what we conclude from these findings for our own projects. We publish what we can back with evidence.