German Building Modernisation Act criticized for heating and biofuel rules

The Federal Council and parliamentary committees have raised extensive criticism of the Gebäudemodernisierungsgesetz (GModG). They point to the removal of mandatory heating‑system advice, the lack of integration with a strategic heat‑plan, and uncertain supply for the “Biotreppe” (bio‑fuel ladder). Jutta Betz, chair of the German Energy Consultant Network (DEN), warned that “the biotreppe is a costly undertaking for the climate, the state finances and the consumer”. DEN also opposes the proposed “fleet approach” for large housing providers, calling it a source of legal confusion.

Industry groups echo these concerns. The Bundesverband Nachhaltige Wirtschaft (BNW) demands transparent cost‑benefit analyses before any heating decision, linking the Building Energy Act (BEG) to CO₂‑price revenues and a post‑implementation adjustment mechanism to keep the law aligned with climate targets. BNW’s Katharina Reuter stressed that “without a market‑ and quantity‑impact assessment there can be no start of the bio‑ladder”. Both associations argue the current draft slows Germany’s heat transition, risks continued dependence on fossil imports and could jeopardise climate‑goal achievement.

Suggested reforms include reinstating mandatory advisory services, refining the regional implementation clause to avoid a regulatory patchwork, and ensuring high efficiency standards for direct‑current electric heating. The debate centers on balancing climate ambition with economic feasibility for landlords, tenants and the building sector at large.