Direktvermarktung in Germany

Executive Summary

Two developments are reshaping Direktvermarktung as a market function in Germany.

The first is regulatory. On 22 January 2026 the Federal Ministry of Economic Affairs and Energy (BMWE) circulated a working draft of the EEG 2027 that introduces a mandatory two-sided contract-for-difference for new installations above 100 kW from 2027, with a clawback "refinancing contribution" above the strike price (Orrick / Freshfields / Taylor Wessing analyses, 2026). Asset owners would be permitted to opt out of EEG support within the first ten years of commissioning, though this exit is irreversible. The draft also establishes Resilience Auctions under the EU Net-Zero Industry Act, with initial annual volumes set at 3,500 MW for onshore wind and 500 MW for solar. The reform consultation runs through 2026, the parliamentary timeline is uncertain, but the direction of travel is clear.

The second is operational. The integrated Direktvermarkter, those running a 24/7 trading floor with proprietary algorithms across Day-Ahead, the three pan-European intraday auctions (IDA1/IDA2/IDA3), continuous intraday (XBID), the Regelenergie product family (aFRR/mFRR/FCR), and Redispatch 2.0 / BTR services, now extract materially more value per MWh than providers running a partial stack. Modo Energy's analysis of the post-October-2025 quarter-hour transition, combined with TSO transparency data, places the differential between top-tier and median provision at 8–15% of total revenues for comparable wind and solar assets.

The asset-owner question used to be: how do I stay compliant with EEG and minimise direct-marketing fees? In 2026, it has become: how do I maximise capture rate, minimise imbalance leakage, and position my assets for the post-reform architecture? Pricing per MW, contract length, and basic reporting, the criteria that mattered in 2022, now understate the variables that determine returns through 2030.

This article maps the regulatory and capability landscape, sets out the operational layers Direktvermarkter now own, and lays out a framework for plant operators and IPPs evaluating providers over the next 18 months.

Pure Energy · an integrated direct marketer (Direktvermarkter), top-tier algorithmic power trader and originator across the renewable energy value chain, manages a 4.2 GW renewable portfolio in Germany and trades 7.5 TWh annually across Day-Ahead, Intraday and Regelenergie markets. From Düsseldorf and Monheim am Rhein, the firm sits at the intersection of asset owners, wholesale markets and C&I energy buyers, ranking among Top-20 in European intraday (XBID), Top-15 Direktvermarkter overall, and Top-10 in wind-energy-only. The analysis below reflects what we observe across our portfolio and our trading desk in mid-2026.

01 · Where the Direktvermarktung market stands

Three numbers describe the German Direktvermarktung market in 2026.

About 86% of utility-scale and commercial installed renewable capacity in Germany now flows through Direktvermarktung. The 2016 EEG reform mandated direct marketing for new assets above 100 kW. The 2023 acceleration brought most of the existing fleet across. The feed-in tariff regime that defined the previous decade is now a residual, applying mostly to small rooftop PV.

Roughly 150 Direktvermarkter operate in Germany. Some 40 of them carry RE-only portfolios above 100 MW, by ZfK Winterumfrage 2025/2026 estimates. Four sit above 5 GW under management, EnBW, Quadra, Statkraft Markets and Next Kraftwerke, with portfolios in the 7,000–10,000 MW range. The mid-tier (1–5 GW under management) holds another twelve to fifteen providers; Pure Energy belongs here, alongside several others.

The long tail, dozens of Direktvermarkter below 1 GW, often regional Stadtwerke or technology-niche vehicles, faces a structural cost problem. Maintaining a Direktvermarktung book across all market layers has fixed costs that do not scale linearly with portfolio size. Day-Ahead nominations, intraday algorithms, Regelenergie pre-qualification, balancing-group management, Redispatch 2.0 coordination, the unit economics tilt against standalone operation below roughly 500–800 MW under management.

Small Direktvermarkter will not disappear. Many serve their regional bases sustainably on the strength of long-standing client relationships. But for plant operators with assets above 10–20 MW, the choice is increasingly between integrated mid-tier players and the very large incumbents.

The market has stopped fragmenting and started sorting.

02 · What the asset actually earns

The Marktprämienmodell, in its post-2014 form, looks simple on paper. The grid operator pays a Marktprämie equal to the gap between the EEG reference value (Anzulegender Wert, AW) and the monthly average market value (energieträgerspezifischer Marktwert) for the relevant technology. The Direktvermarkter passes the realised wholesale revenue (Börsenwert) through to the asset owner. The two streams together deliver the EEG floor or, with execution, more.

In 2026 the headline figures look like this. Average wind-onshore Marktwert sat at EUR 65–75/MWh through Q1, by BNetzA's monthly publications. PV Marktwert ran lower, EUR 50–60/MWh, depressed by midday cannibalisation. Award values from the most recent tenders cluster between EUR 70 and EUR 90/MWh for wind, somewhat lower for ground-mount PV. And §51 EEG continues to deny remuneration during extended negative-price hours, with the Solarspitzengesetz tightening the rule for new PV from February 2025: revenue stops at the first negative hour, not the sixth.

Three sources of value capture separate a top-quartile outcome from a median one.

The first is market-side execution. The Börsenwert paid to the asset owner depends on what the Direktvermarkter actually realises across Day-Ahead, the three intraday auctions, and continuous intraday. A megawatt-hour produced at 14:00 on a sunny April afternoon might receive EUR -10/MWh, full pass-through of a deep negative-price hour, or EUR +35/MWh, where the trader has shifted intraday positioning to capture an evening price spike. The price signal is the same. The execution is not.

The second is balancing-group efficiency. Forecast errors, schedule deviations, imbalance volumes, each attaches a cost to every megawatt-hour delivered. A tight balancing group, with high-frequency forecast updates and active intraday rebalancing, retains more of the gross revenue. A loose one leaks value through imbalance settlement, year after year, in flows that asset owners rarely track.

The third is Regelenergie participation, where assets qualify. Wind, solar and hybrid assets pre-qualified for aFRR or mFRR earn additional revenue per available MW. Until 2025 this was a niche. With solar entering the aFRR market for the first time in 2026, and 15-minute aFRR products coming in Q3, the participation base widens.

A worked example. Take a 5 MW wind asset in northern Germany, awarded at AW EUR 73/MWh in 2023, producing 12,500 MWh in a typical year:

The Marktprämie is regulatory: it does not move with the choice of Direktvermarkter. Everything else does. An 11.4% differential on a single asset, repeated across a portfolio over a ten-year asset life, finances a meaningful share of the next round of capex.

The Marktprämie sets the floor. The Direktvermarkter sets the ceiling.

03 · The EEG reform draft and what it asks of asset owners

The working draft circulated by the Federal Ministry of Economic Affairs and Energy (BMWE) on 22 January 2026 introduces three changes that bear on Direktvermarktung. The text remains in active consultation through 2026. The parliamentary timeline runs through late 2026, with most provisions targeted from 2027. Read the changes below as conditional on what survives that process.

The first change is the move to two-sided contracts-for-difference for new assets from 2027. Where the current Marktprämienmodell pays top-up only, the new mechanism would also claw back revenue above a defined strike price. The draft tempers the clawback with a corridor, a band above strike within which the operator retains a portion of the upside. For Direktvermarkter, the corridor is the operationally interesting feature. Navigating it in real time requires market intelligence, fast positioning, and the ability to advise asset owners on bid strategies tied to anticipated price regimes. A passive Marktprämie processor adds little in the corridor; an integrated commercial advisor adds quite a lot.

The second change is the perpetual opt-out. Asset owners would be permitted to leave the EEG support regime within the first ten years after commissioning, switching to fully merchant or PPA-based commercialisation. The opt-out matters where long-tenor PPA prices clear above the EEG award, a configuration that has applied to selected wind PPAs in 2024–2026. Once exercised, the election cannot be reversed. So the timing decision is non-trivial, and the asset owner needs counsel from someone who reads both EEG dynamics and PPA markets.

The third change is the replacement of Innovation Auctions with Resilience Auctions. The Innovation Auctions, running since 2018, drew mixed reviews. The replacement targets capacity-aligned procurement of system-useful renewable configurations, typically hybrid PV + BESS or co-located wind + BESS, with explicit grid-stability scoring criteria. Volume targets in the draft are 10 GW per year of onshore wind and 14 GW per year of ground-mount PV, with Resilience Auction volumes still under negotiation. Eligibility for Resilience awards depends on asset configuration choices made at greenfield stage, which means the Direktvermarkter needs to be at the table during structuring, not after commissioning.

Taken together, the three changes shift bargaining power toward asset owners with sophisticated commercial-management partners. Contracts written before 2025 may not anticipate the post-2027 environment. Asset owners with rolling reviews in 2026–2027 should evaluate provider capability against the reform's specific architecture, not against the legacy model.

04 · The 24/7 algorithmic trading divergence

Of every operational shift in Direktvermarktung over the past three years, the most consequential has been the bifurcation between integrated 24/7 algorithmic providers and providers running a partial market stack. The technical drivers are well understood inside trading desks. The commercial consequences are still landing on parts of the asset-owner community.

The German wholesale market in 2026 has three temporal product layers, and a Direktvermarkter who works only the first earns very different outcomes than one who works all three.

Day-Ahead clears at quarter-hour granularity since October 2025, replacing the prior hourly product. The transition more than doubled the granularity of available price signals. For any provider not operating at 15-minute resolution, the value of asset-specific forecast accuracy roughly doubled overnight.

The pan-European intraday auctions IDA1, IDA2 and IDA3 came in over June 2024 and the months following. The three auctions clear quarter-hour products at three discrete gate-closure points before delivery, layered between Day-Ahead and continuous intraday. The capable Direktvermarkter runs algorithms that systematically reposition between Day-Ahead and the IDA windows, picking up the sawtooth patterns that emerge as quarter-hour reality clashes with hourly DA legacy positioning.

Continuous intraday (XBID) takes the position to within five minutes of delivery. For wind and solar, where short-term forecasts are imperfect by nature, XBID is where the trader recovers value the day-ahead fix-and-forget approach leaves on the table.

Behind these three product layers sits the Regelenergie market family, aFRR, mFRR, FCR, with its own pre-qualification cycles, settlement rules and product variants. Increasingly, Regelenergie integrates with Redispatch 2.0 through BTR (Betreiber technische Ressource) coordination, putting the trading layer and the operational layer on the same workflow.

A Direktvermarkter running the full stack, algorithms across DA, IDA1/2/3, continuous intraday, Regelenergie, and Redispatch coordination, with a trading desk where humans supervise and override the algorithms in fast-moving conditions, extracts a quantifiably different revenue per MWh than one running Day-Ahead with manual intraday adjustment.

The differential is in the data. Modo Energy's analysis of the post-October-2025 quarter-hour transition, combined with TSO transparency data on imbalance settlement, places top-tier total revenue capture 8–15% above median performance for comparable wind and solar assets. For a 50 MW wind portfolio earning roughly EUR 80/MWh at 22% capacity factor, an 11% differential equates to about EUR 850,000 per year of retained or forfeited revenue. Across ten years of asset life, the gap pays for the wind park's mid-life inverter overhaul and most of a repowering refit.

The reason the divergence is structural, not just operational, is fixed cost. A 24/7 trading floor with proprietary algorithms requires investment running into the low millions of euros per year for systems, connectivity, and people. A regional Direktvermarkter with 300 MW under management cannot economically run that stack. The choice is to accept lower capture rates or to outsource execution to a wholesale partner, with the cost layer and the loss of control that imply.

For asset owners and IPPs, the question of "which Direktvermarkter" has become a question of what trading capability the provider actually owns end-to-end.

Day-ahead-only commercialisation has dropped out of the competitive set for German renewables. The revenue now builds across continuous intraday and the IDA auctions, day after day, and that is increasingly where the trader earns or loses the year.

05 · The Redispatch 2.0 and BTR layer

Redispatch 2.0 has been mandatory since October 2021, with rolling refinements through 2024–2026. It is the operational layer asset owners most often underestimate during Direktvermarkter selection.

The mechanism reads simply enough. TSOs and DSOs identify grid congestion in advance, instruct selected assets to reduce or increase output, and compensate operators for the resulting deviations. The execution is harder than the description. Schedule submissions, real-time deviations, settlement reconciliation, each demands precision, and each consequence of poor execution lands directly on the asset's revenue line.

The BTR (Betreiber technische Ressource) role handles Redispatch 2.0 instructions on behalf of asset owners. A Direktvermarkter that integrates the BTR function into its core service, rather than referring asset owners to a separate provider, gives the asset owner a single counterparty for the full operational stack, faster reconciliation, and reduced settlement leakage at the seams between trading and operations.

In Pure Energy's portfolio, this integration has been operational since the Adwind Renewables partnership announced in September 2024, where Adwind serves as the BTR provider and Pure Energy as the integrated Direktvermarkter, managing 1,000 MW of asset operations under unified workflow. Other Direktvermarkter operate alternative integration models or refer asset owners to third-party BTRs. The model varies. The general point is that asset owners with separated trading and BTR providers report higher settlement frictions than those with integrated counterparties, a cost that, individually modest, compounds across a portfolio over time.

06 · Regelenergie reaches renewables

The Regelenergie market, historically conventional thermal and BESS territory, has been opening to renewables. Three developments mark 2026.

Solar assets entered the German aFRR market for the first time, both individually where pre-qualified and as part of pooled VPP structures. Pre-qualification work, telemetry, control interface, response testing, has become more standardised than it was three years ago, though it remains real engineering. The revenue uplift, depending on hours of qualified availability, ranges from EUR 1,500/MW·a to EUR 4,000/MW·a for solar assets with appropriate inverter capability.

Wind aFRR and mFRR participation continues to expand. Pre-qualified BESS capacity in Germany is roughly doubling year-on-year. Wind assets in coastal regions, with high capacity factors and behind-the-meter flexibility, are increasingly entering the secondary control market. Modo Energy projects that pre-qualified capacity will exceed total FCR demand in 2026, compressing FCR margins and pushing marginal value into aFRR and mFRR.

Fifteen-minute aFRR products arrive in September or October 2026, replacing the prior four-hour minimum block. The change benefits renewables and BESS most. Assets that respond to fast-changing renewable feed-in patterns become eligible for products that previously required multi-hour commitments they could not credibly offer. Wind and solar assets currently outside the Regelenergie stack gain economic participation that did not exist before.

The capability question for asset owners reads simply: does the prospective Direktvermarkter qualify assets for Regelenergie as a standard service, or as an add-on? Standard inclusion implies the Direktvermarkter owns the institutional infrastructure for pre-qualification testing, ongoing certification, real-time bid management, and settlement reconciliation. Add-on positioning typically means a referral to a third party, with the cost layer that introduces.

Regelenergie is not the largest revenue layer for most wind and solar assets, it sits in the single-digit percentage range of total revenue today. It is rising structurally. A Direktvermarkter without the capability is leaving asset-owner revenue uncollected.

07 · A decision framework for asset owners and IPPs

Six decisions face asset owners and IPPs evaluating Direktvermarktung in 2026. They are best read as a sequence; the answer to one shapes the next.

Decision 1: When to evaluate or rotate. Most Direktvermarktung contracts run three to five years with auto-renewal clauses. Trigger events for re-evaluation: contract renewal within twelve months; meaningful change in portfolio composition (additions, repowering, BESS co-location); a regulatory shift such as the EEG reform now in consultation; or a measurable decline in observed capture rates against portfolio peers. The 2026–2027 window contains all of these for many German asset owners.

Decision 2: Single-market or multi-market commercialisation. A Direktvermarkter running Day-Ahead with manual intraday adjustment differs structurally from one running integrated DA + IDA1/2/3 + continuous intraday + Regelenergie. The total commercial value differential between the two is empirically 8–15%, as Section 04 sets out. For assets above roughly 5 MW, multi-market provision is the economic answer in almost every case. The question becomes provider quality, not service tier.

Decision 3: Direktvermarkter scale tier. Each tier delivers a different proposition. The top-five (above 5 GW under management, EnBW, Quadra, Statkraft Markets, Next Kraftwerke and similar) offer scale-driven cost efficiencies and broad operational stack. The mid-tier (1–5 GW, including Pure Energy and several established providers) offers integrated capabilities with closer commercial relationships and more flexible structuring. The long tail (below 1 GW, often regional Stadtwerke) serves specific use cases, typically where regional commercial relationships or technology-niche specialisation matter more than capture-rate optimisation.

Decision 4: Bundled or unbundled services. The full-stack offering covers Direktvermarktung, Regelenergie qualification, Redispatch 2.0 / BTR integration, and portfolio reporting. Some Direktvermarkter unbundle these and refer asset owners to third parties; others integrate them as standard. Bundled provision typically reduces total cost of ownership and operational friction. Unbundled provision can suit asset owners with internal operational capability who want specialised providers per layer. For most asset owners, bundled is the default answer.

Decision 5: Reporting transparency. Modern Direktvermarktung reporting includes near-real-time portfolio dashboards covering asset-level production, market revenues, imbalance attribution, Marktprämie reconciliation, and audit-grade settlement traceability. Providers who treat reporting as a value-add rather than a regulatory minimum signal where else they invest. The quality of the asset-owner-facing dashboard is a reasonable proxy for the quality of the underlying operations.

Decision 6: Provider selection criteria. With Decisions 1–5 in place, the choice between qualifying Direktvermarkter narrows to operational and strategic criteria. When the gap between providers accounts for 8–15% of attainable revenues, route-to-market selection moves out of procurement and into the strategy office. The questions plant operators and IPPs should put to providers:

• Does the provider operate a 24/7 trading floor with proprietary algorithmic systems, or is the algorithmic layer outsourced or white-labelled?
• Does it co-optimise DA + IDA1/IDA2/IDA3 + continuous intraday + aFRR within a single integrated stack?
• Does it offer Regelenergie qualification and Redispatch 2.0 / BTR services as standard, or as add-ons?
• Is the reporting transparent and operator-accessible, real-time portfolio dashboards, audit-grade settlement?
• Can it connect the asset owner to corporate offtake structures (PPAs, full-renewable supply for C&I) when revenue diversification becomes the strategic question?

Pure Energy operates as a one-stop-shop, a bridge between renewable assets, wholesale markets and C&I energy buyers, anchored by 4.2 GW under management in Germany, 7.5 TWh in annual trading volume, and a Top-15 Direktvermarkter / Top-10 wind-energy ranking. For asset owners and IPPs evaluating their commercialisation choices in 2026–2028, the integration we run across these capabilities is, by our reading of the market data above, the kind of partner the next regulatory and operational cycle rewards.

08 · Outlook 2026–2030

Three theses for the next eighteen to forty-eight months.

Thesis 1: EEG reform shifts bargaining power. If the reform passes broadly as drafted, the post-2027 environment rewards Direktvermarkter that can navigate two-sided CfD corridors, advise on opt-out timing, and structure assets for Resilience Auction eligibility. Asset owners gain leverage in renewal negotiations because the criteria distinguishing capable providers from incapable ones become more visible. Mid-tier integrated providers, those with full operational stacks but commercial flexibility, should gain share at the expense of both pure-scale players and the long tail.

Thesis 2: Multi-market integrated providers consolidate share. The 8–15% total revenue differential between integrated and partial-stack providers should widen as the quarter-hour DA, the IDA windows, and the 15-minute aFRR product mature through 2027–2028. Asset owners who switch to integrated providers will see incremental revenue uplift in their first full year under the new arrangement. Those who do not will watch relative under-performance accumulate, year after year, in flows they may not even be measuring.

Thesis 3: Direktvermarktung becomes a strategic procurement decision. Treating Direktvermarktung as "a compliance service one buys at the lowest price" reads, in 2026, like an artefact of the previous decade. By 2028, the most sophisticated asset owners and IPPs will run Direktvermarkter selection as a strategic procurement exercise, multi-stage RFP, capture-rate benchmarking, operational due diligence, rather than as the renewal of a default vendor relationship.

09 · Closing

Direktvermarktung began as a compliance mechanism. Through the 2014 and 2017 reforms, it became the dominant route to market for German renewables. With the 2026 EEG reform draft and the maturation of the integrated trading stack, it now functions as a competitive asset on the asset owner's balance sheet, an asset that performs well or badly depending on the provider behind it.

The two forces this article has set out, regulatory reform reshaping the commercial architecture, capability divergence reshaping the operational stack, reinforce each other. The reform privileges providers with sophisticated commercial-management capability. The capability gap concentrates that sophistication in fewer integrated operators. The result, taken together, is to turn the choice of Direktvermarkter into one of the most consequential decisions a German renewable asset owner makes.

For plant operators with renewals coming up, and for IPPs structuring portfolios for the next decade, the questions to ask a provider have changed. Asset owners who ask them will compound revenue advantage across the maturity cycle. Those who renew on legacy terms will discover, year after year, that their assets earn less than they should.

Methodological notes and sources

All market data in this article are publicly published. No internal Pure Energy positions, forecasts, or trading statistics were used. The article discusses public market structures and regulatory developments. It does not constitute investment or legal advice. Specific decisions about Direktvermarktung structuring require an asset-, regulatory-, and contract-specific case-by-case assessment.

Primary sources:

• Bundesnetzagentur (BNetzA). EEG reform draft consultation, January 2026; monthly Marktwert publications 2025–2026; Redispatch 2.0 framework communications.
• Federal Ministry of Economic Affairs and Energy (BMWE). EEG 2027 working draft text, 22 January 2026.
• TSOs. TransnetBW, 50Hertz, TenneT, Amprion, Redispatch 2.0 operational guidance, transparency platform data 2025–2026.
• Regelleistung Online & regelleistung.net. aFRR/mFRR/FCR auction data; 15-minute aFRR product specifications, 2026; pre-qualification statistics.
• EPEX SPOT. Quarter-hour day-ahead auction (since October 2025); IDA1/IDA2/IDA3 product specifications; XBID continuous intraday data.
• ZfK (Zeitung für kommunale Wirtschaft). Direktvermarktung Winterumfrage 2025/2026; ranking analysis, December 2025.
• Energie & Management (E&M). Branchenumfrage 2026; sector commentary 2025–2026.
• Modo Energy. German power market analyses; intraday capture-rate analytics; Regelenergie market commentary, 2025–2026.
• Capstone DC. Europe Battery Storage Edge, Insights 2025; renewable capture-rate research.
• Wood Mackenzie / Rystad / SolarPower Europe. European renewable outlook 2025–2029.
• Sector law firms. Gleiss Lutz, Baker McKenzie, Herbert Smith Freehills Kramer, BBH (Becker Büttner Held), EEG reform legal updates, 2026.
• Industry media. pv magazine Deutschland, Erneuerbare Energien Magazin, Energy-Storage.News, Montel News, Energate Messenger.

About Pure Energy

Pure Energy is an integrated direct marketer (Direktvermarkter), top-tier algorithmic power trader and originator across the renewable energy value chain. Based in Düsseldorf and Monheim am Rhein, Pure Energy GmbH manages a 4.2 GW renewable portfolio in Germany, trades 7.5 TWh annually, and ranks among Top-20 in European intraday (XBID), Top-15 Direktvermarkter overall and Top-10 in wind-energy-only. With operations across Germany, the Netherlands, Sweden, Finland, Estonia and Japan, and expansion underway in France, Italy and the United Kingdom, Pure Energy serves as a one-stop-shop, a bridge between renewable energy assets, wholesale power markets, and C&I energy buyers.

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