WPG heat-planning: city plans due 30 Jun 2026; district-heat roadmaps due 31 Dec 2026—what to check for your building and street
Under Germany’s Wärmeplanungsgesetz (WPG), large cities had to adopt heat plans by 30 June 2026; heat‑network operators must publish decarbonisation roadmaps by 31 December 2026. Here’s the address‑level due‑diligence.
What the WPG requires—and the two 2026 deadlines
Germany’s Act on Heat Planning and the Decarbonisation of Heat Networks (Wärmeplanungsgesetz, WPG) has been in force since 1 January 2024. It creates a nationwide framework for municipal heat plans and legally staged decarbonisation of district‑heating systems. The law text and the official ministry pages confirm this entry into force and scope. Cities with more than 100,000 inhabitants (as of 1 January 2024) had to complete a municipal heat plan by 30 June 2026; smaller municipalities have until 30 June 2028. The plan must be formally adopted by the competent local body and then published online. Six months after each deadline the federal ministry must make completed plans centrally accessible online. These dates matter for buyers: by the second half of 2026, most large‑city plans should be visible and searchable.
The second 2026 obligation sits with heat‑network operators. Every operator whose network is not yet fully supplied by renewable heat or unavoidable waste heat must prepare, submit to the state authority, publish on its website, and then review at least every five years a “Wärmenetzausbau‑ und ‑dekarbonisierungsfahrplan” (network expansion and decarbonisation roadmap) by 31 December 2026. The WPG’s Annex 3 sets out the required content of these roadmaps. State authorities (example: Bavaria’s LMG) repeat the deadline and the publication duty and explain limited exemptions where a BEW‑funded transformation plan exists or the network is very small.
Beyond planning, the WPG imposes binding performance milestones on district‑heating: at least 30% renewable or waste heat from 1 January 2030, 80% from 1 January 2040, and complete climate‑neutral supply by 31 December 2044. Under §29, customers connected to a network that fails to meet the milestones may demand proof and, in certain cases, have a right to disconnect. These targets and rights shape risk for existing and planned connections.
Address-level due diligence: what to verify for your building and street
1) Is there a formally adopted heat plan? Confirm that the municipality has adopted (“beschlossen”) a heat plan under §13(5) WPG and published it online. For cities over 100,000 residents, the deadline was 30 June 2026. Check the city’s heat‑planning portal and, from early 2027 onward, the federal central page mandated by §34 WPG. Example publications exist for Berlin and Hamburg in 2026.
2) What zone is your address in? Heat plans must divide the territory into “voraussichtliche Wärmeversorgungsgebiete” for 2030, 2035 and 2040 (§18 WPG). Find your parcel or street on the plan map and note the indicated supply type: district‑heating area, hydrogen‑network expansion area, or decentralised supply area (often heat pumps). The plan should also show “review” or “unsuitable” areas from the suitability check (§14). This zoning does not itself force you to use a specific system (§18(2), §27(1)), but it strongly signals public‑sector priorities and utilities’ investment sequencing.
3) Is there a §26 decision designating your area? A separate administrative act may designate an area for new or expanded district‑heating or as a hydrogen‑network expansion area. This decision does not impose a direct connection obligation (§27), but it must be considered in planning and permitting and often governs Building Energy Act interactions. Record the date and the exact boundaries, because later changes can alter your options.
4) Has your local heat‑network operator published its roadmap? Under §32 WPG the operator must file and publish a network expansion and decarbonisation roadmap by 31 December 2026. Verify it exists on the operator’s website, and that it covers: defined network boundaries and length; three‑year historic heat sales by area; current generation mix; the pathway to meet 30% (2030), 80% (2040) and full decarbonisation by 31 December 2044; phasing‑out plans for fossil CHP; any reliance on hydrogen or synthetic fuels limited to peak/residual load, as Annex 3 prescribes. Note review cycles (at least every five years) and any interim milestones.
5) Are there extensions or “complex measure” filings? §29 allows limited extensions to 2034/2044 in hardship cases and, for complex measures, if notified by 31 December 2026 with construction started by 31 December 2027. Ask the operator (and the state authority) whether such notices were filed, because they push back the operator’s compliance dates and may slow local connection timelines.
6) Customer rights and local duties. From 2030, customers may request proof that the network meets §29 milestones and may have a right to disconnect if it does not (§29(7)). Separate local bylaws on mandatory connection/use (Anschluss‑ und Benutzungszwang) may still apply; check municipal statutes before assuming you can disconnect.
7) Practical red flags. Hydrogen for household heat is contested economically in many analyses. Bundestag materials suggest it will only be viable in special cases. If your street is in a designated hydrogen area, treat timing and cost assumptions cautiously and demand the operator’s evidence in the roadmap.
8) Who to ask. Use the city’s heat‑planning portal; the operator’s roadmap page; your state’s energy‑agency hub (e.g., NRW, Bavaria, Rheinland‑Pfalz publish WPG guidance); and, if you plan capex, commission a German TGA engineer for building‑level options. For questions on local connection bylaws, consult a German public‑law attorney.
How to find the documents and read them fast
- City heat plan: Start on the municipal portal (examples: Berlin’s 2026 plan; Hamburg’s adopted plan and portal). Look for: the legend of supply zones, any §26 designations, and the implementation strategy (§20 WPG). Save the adoption date and map version.
- Federal central listing: §34 WPG requires the federal ministry to make completed municipal plans centrally accessible online six months after the §4(2) deadlines (i.e., by end‑December 2026 for large cities). Use it to cross‑check that you have the latest plan.
- Operator roadmap: Go to your heat‑network operator’s website and find the “Wärmenetzausbau‑ und ‑dekarbonisierungsfahrplan.” Annex 3 requires, among other items: precise network definition; three‑year heat‑sales maps; an energy and GHG balance; technology pathways; phase‑out of fossil CHP; strict limits on using hydrogen/synthetic fuels (only for peak/residual load). If missing, contact the operator and the competent state authority named in your state regulation (Bavaria publishes a dedicated portal and confirms the publication duty).
- Performance targets and rights: Note the dated thresholds—30% by 1 January 2030, 80% by 1 January 2040, 100% by 31 December 2044 (§§29–31). For existing connections, keep proof requests and the disconnection right in mind (§29(7)).
Risk note: Neither the zoning in a heat plan (§18) nor a §26 designation creates a direct obligation to connect (§27). However, they often influence permits and grid‑investment sequencing. Do not assume a fast, cheap district‑heat connection solely because your street is shaded as a “Wärmenetzgebiet.” Demand the operator’s schedule and capex in the roadmap. Where a hydrogen area is proposed, treat that as higher‑uncertainty planning and check the operator’s evidence and the city’s rationale.
Who should you consult?
- Municipal planning office or heat‑planning portal: confirm adoption date, map layers, and any §26 designation affecting your block. - Heat‑network operator: obtain the published §32 roadmap and ask specifically about your street’s connection window and planned generation mix. - State energy‑agency hub: many states provide WPG guidance and contact points (examples cited below for NRW, Bavaria, Rheinland‑Pfalz, Schleswig‑Holstein). - Technical advisor: a German TGA‑planner (building services engineer) to test heat‑pump vs. district‑heat economics against the plan’s zoning and the operator’s roadmap. - Legal counsel: a German public‑law lawyer to check any municipal connection‑and‑use bylaw before assuming you can disconnect or must connect.
This article is a general guide, not legal or investment advice.
Nothing on this page is investment, tax or legal advice. Price bands are indicative asking prices and disagree between sources by design. Verify every figure with a qualified German notary, tax adviser (Steuerberater) or lawyer before committing capital.