Bundeskartellamt and the German Federal Network Agency (“Bundesnetzagentur”) conducted a joint inquiry into the extraordinary price increases that occurred in the short-term wholesale electricity market during November and December 2024.
The investigation found that renewable energy production was very low between November 5-7, 2024, and December 11-12, 2024, due to low levels of sunlight and wind activity (“dunkelflaute”). It was determined that market prices briefly exceeded the threshold of €300/MWh during the period in question, rising to €936/MWh at certain times. In contrast, the daily average wholesale electricity price for 2024 was reported to be around €79/MWh.
The Bundeskartellamt and Bundesnetzagentur stated that they had investigated the period during which these price peaks occurred and found no evidence that the high prices during this period were the result of major electricity producers deliberately limiting capacity, restricting supply, or manipulating the market. It was stated that during the period under review, the five major producers in Germany (EnBW, LEAG, RWE, Uniper, and Vattenfall) had largely utilized their existing production capacities, had not engaged in any market manipulation within the scope of REMIT, and therefore no behavior prohibited under competition law had been identified.
However, the Bundeskartellamt and the Bundesnetzagentur pointed out that the system's necessity to use all its flexible and conventional resources during hours when very low renewable production coincided with high demand indicated a structural vulnerability that could lead to similar price peaks in the future. Therefore, the importance of regulatory steps to increase controllable capacity and make the demand side more flexible was emphasized. It was also noted that upcoming tenders are important for implementing new controllable capacities to reduce the high market concentration in the electricity generation market.
In conclusion, it was stated that the wholesale electricity price peaks observed in November and December 2024 did not stem from market behavior prohibited under competition law or energy market regulations in the examined section; however, certain individual issues will continue to be monitored in the coming period.
(Bundeskartellamt – 21.10.2025)
NAZALI TAX & LEGAL