Energy Suppliers 2026: Tariff Advertising under EmpCo

The Bundesnetzagentur (BNetzA, Federal Network Agency) as a new hurdle: Since 2024, the BNetzA has tightened its supervisory regime towards energy suppliers. In 2024, fines were imposed for the first time on tariff providers advertising with “green electricity” but actually “greenwashing” grey electricity via certificates of origin.

Electricity tariffs: Advertising “100% green electricity” solely through GoO/HKN is liable to be subject to warning letters under Section 5 UWG and the EmpCo Directive (EU 2024/825). Permitted: “Electricity from 100% renewable sources with concrete plant IDs”. Recommended seals: Grüner Strom Label (GSL), ok-power, TÜV SÜD EE01.

Gas tariffs: “Climate neutral natural gas” through offsetting is a per-se prohibition from 2026 (EmpCo). Permitted: Specify the biogas proportion as a percentage, disclose the methodology. Recognised: Biogasregister Deutschland (dena-certified).

Heat tariffs: “Carbon neutral heat” through carbon offsetting is critical according to EmpCo Annex I No. 4b. Permitted: Heat generation mix with kWh proportions per source.

Electricity mix obligations (§ 42 EnWG): Breakdown of energy sources in %, CO₂ emissions per kWh, radioactive waste per kWh, and for green electricity, the generation plant mix.