Initial steps as a PV operator
You have now purchased a photovoltaic system. What next? The following checklist will give you an overview of what needs to be taken care of first, as seen from the perspective of an operator in Germany.
You’ve made a direct investment and become the operator of a PV system. Before beginning permanent regular operation, there are some formalities to take care of and organisational structures to establish. These differ in part depending on whether you have acquired a new or an existing system.
Register with the Federal Network Agency (Bundesnetzagentur)
For operations in Germany, you are required to report new systems:
- Register the photovoltaic system in the Federal Network Agency’s core energy market data register (Marktstammdatenregister) no later than the day of commissioning (max. two weeks before). The EEG requires this, or your entitlement to EEG remuneration will expire. The registration obligation also applies to electricity sold to tenants and other forms of direct marketing.
There is also a reporting requirement for existing systems:
- Consult the previous owner and register the change of operator in the core energy market data register
- Report any extensions to existing systems.
The reports can be submitted to the Federal Network Agency online. As a system operator, you must do this yourself.
Register with the grid operator
All electricity grid operators in Germany are obliged to purchase the electricity produced by photovoltaic systems and pay out the EEG feed-in tariffs.
Reporting new systems:
- Before installation, submit an application for grid connection. Afterwards, the grid operator has the right to conduct a grid compatibility test to determine whether the grid can accommodate the electricity. No problems should be expected for small systems with up to 10 kWp output. Legally, the grid compatibility test may take up to eight weeks.
- Register the completed photovoltaic system with the grid operator and provide the name of the person responsible for the system.
- Commission the completed PV system and create the commissioning report.
- For direct marketing, test the controllability.
In the case of existing systems, it is enough to notify the grid operator of the change of operator and, if applicable, any new persons now responsible for the system.
In order to better manage bottlenecks in the grid, significantly more systems in Germany will be integrated into the grid management system starting from the 1st of October 2021.
Operators of systems with an installed capacity of 100 kWp or more will be obliged to either take on the newly established market roles of Einsatzverantwortliche (EIV, German for Resource Providers) and Betreiber der technischen Ressource (BTR, German for Producers) themselves, or delegate these roles to a service provider.
Report to the tax authorities
The operation of a photovoltaic system that feeds electricity into the public grid is a commercial activity subject to turnover tax.
- Register or re-register your business with the tax authorities.
- Register for IHK membership (Industrie- und Handelskammer; the Chamber of Industry and Commerce). You will be contacted for this. For smaller PV systems, compulsory membership is non-contributory.
- You may be exempt from turnover tax if you generate less than €17,500 in turnover in the year of commissioning and less than €50,000 in subsequent years.
Trade tax is also due from an annual surplus of €24,500. The 70/30 rule applies in this case: 70% of the trade tax is paid to the local municipality and 30% is paid to the company’s registered office.
Accept the photovoltaic system
The photovoltaic documentation and acceptance tests must at least comply with the normative requirements of DIN VDE 0100-600 and DIN VDE 0126-23. Additional audit requirements can be agreed upon in the contract. You can find out in more detail what the documentation includes in chapter 4.2.
For new systems, the installer must fully check the function of the system, carry out and document commissioning, fully document the system technology, instruct you in system operation, and transfer manufacturer guarantees. Your tasks are then:
- Accept the PV system, if possible accompanied by an independent expert. The quality of construction, compliance with normative requirements, 1:1 implementation of the planning, commissioning documentation, technical documentation, and failure-free operation are all checked.
- Set up secure IT infrastructure and link the system to your monitoring portal. If desired, conclude a contract for technical management for the operating phase. This should include monitoring, failure management, inspection, maintenance, periodic inspections according to DGUV regulation 3 (Deutsche Gesetzliche Unfallversicherung, German Social Accident Insurance), and key figure reporting.
For existing systems, it is wise to have an independent expert examine the condition of the system and carry out technical due diligence prior to purchase.
Take out an insurance policy
Insuring new systems:
- Research insurance conditions at an early stage so that you can implement any insurance requirements, such as camera surveillance or module theft protection, during the construction phase.
- Take out liability insurance to cover any damage that the PV system may cause.
- Consider taking out electronic equipment insurance along with loss-of-profits insurance. This covers any damage to the system caused by external influences (weather conditions, vandalism) and component theft, and would also cover loss of income.
Insuring existing systems:
- Check whether existing insurance policies can be taken over or whether it is possible/meaningful to take out a new policy at better conditions.
Establish contract management
- File all contracts relevant to operation clearly.
- Establish contract management so that opportunities for cost reductions can be identified and the fulfilment of complete service scopes can be verified.
- Set up and maintain liquidity planning with monthly review of all income and expenditure.
- Define target figures for your future financial controlling. This is fundamental to recognising the need for action and creating reporting.
For new systems:
- Conclude the contract with the direct marketer.
- If necessary, obtain approval from the financing bank.
- Have the direct marketer set up and test the system’s controllability.
For existing systems, check whether the direct marketing contract can also be assumed. If necessary, check alternatives so that better economic conditions can be obtained.
This article was written with the support of Mario Wulff, Head of Commercial Management at greentech.
To read the original article in German, click here.
This article was published in our investment guide. For all other articles and information on Direct investment in commercial-sized photovoltaic systems, please visit: Milk the Sun – PV Investment Guide.