Amendment to the Building Electromobility Infrastructure Act (GEIG) – increasing obligations regarding charging infrastructure in buildings

Briefing

With the planned amendment to the Building Electromobility Infrastructure Act (GEIG), the legislator is significantly tightening the requirements for charging and cabling infrastructure for electric vehicles. In addition to new-build and renovation projects, larger existing buildings will also come under greater scrutiny from 2027 onwards. Companies with office, retail, logistics or other non-residential buildings should incorporate this development into their site and investment planning at an early stage to avoid retrofitting and compliance risks.

The GEIG as a key component of the e-mobility strategy

The GEIG has been in force since 2021 and transposes key provisions of the EU Energy Performance of Buildings Directive (EPBD) into German law. The aim is to systematically expand charging infrastructure in and around buildings, thereby promoting charging at home and at work. It specifically addresses:

Owners of residential and non-residential buildings with parking spaces,
Project developers and investors,
companies with large staff and customer car parks,
the public sector as building owners.

Against this background, the Federal Ministry for Economic Affairs and Energy (BMWE) has presented a draft bill to amend the Building Energy Act, GEIG and other regulations. The draft is currently undergoing inter-ministerial consultation; a consultation with industry associations is taking place in parallel. In terms of content, it builds on the key points already communicated regarding the ‘Building Modernisation Act’ (GModG) and serves to implement the amended EPBD, including its requirements for sustainable mobility.

Current legal situation: GEIG today

The GEIG currently regulates the provision of the following in buildings:

cable infrastructure (in particular, empty conduits for the subsequent laying of cables) and
charging points (charging facilities for electric vehicles),

and links the obligations to:

the type of building (residential vs. non-residential),
the occasion (new build or ‘major renovation’) and
the number of parking spaces.

The obligations are generally directed at the property owners. Exceptions are provided for in certain circumstances (including predominantly owner-occupied non-residential buildings of SMEs).

The requirements are backed by provisions for fines; breaches can be punished with substantial fines.

Planned amendment: What is set to change?

The GEIG amendment essentially pursues three objectives:

Implementation of the new EPBD requirements, particularly regarding sustainable mobility.
Strengthening the expansion of charging infrastructure in and around buildings through stricter minimum requirements.
Technological advancement through the introduction of ‘smart charging’.

Introduction of ‘smart charging’:

The draft introduces the concept of ‘smart charging’ for the first time. According to this, smart charging occurs when the intensity of the current supplied to the battery is dynamically adjusted on the basis of electronically transmitted information.

In concrete terms, this means:

In future, charging points must be capable of being integrated into a charging management system,
they must be capable of responding to external signals (e.g. grid load, prices, control commands),
and thus avoid peak loads and charge in a way that benefits the grid.

Newly installed or replaced charging points should provide this technology as standard. For businesses, this is not merely a compliance issue but also influences the selection of hardware and backend systems, as well as integration into energy management and smart meter structures.

Stricter requirements for cable and pre-cabling infrastructure

The draft makes it clear that, in future, the cable infrastructure must be dimensioned in such a way that the legally prescribed number of charging points can be used simultaneously and efficiently. It is therefore no longer simply a matter of providing individual empty conduits, but of a viable overall concept (grid connection, sub-distribution, space reserves, etc.).

In addition, the role of pre-cabling is being strengthened: some parking spaces are to be equipped not only with empty conduits, but with pre-installed cable routes extending right up to the vicinity of the parking space. This is intended to enable the subsequent installation of further charging points in a cost-effective manner.

New thresholds and quotas for parking spaces

The planned changes to parking space thresholds and equipment quotas are particularly relevant in practice. Both residential and non-residential buildings will be required to install a certain number of charging points and corresponding pre-cabling from a lower number of parking spaces than previously.

This marks a shift in the system: from isolated ‘symbolic charging points’ to a comprehensive infrastructure designed to realistically reflect the rise of electric mobility.

Focus on existing buildings – additional obligations from 2027

In addition to new builds and major renovations, larger existing buildings will also face stricter requirements from 1 January 2027. Additional requirements are planned for buildings with a high number of parking spaces, such as:

a minimum quota of parking spaces with wiring infrastructure or pre-cabling, and/or
a minimum proportion of charging points to be actually installed (e.g. one in ten parking spaces).

Details may still change during the legislative process; however, it is clear that the legislator no longer wishes to limit larger building stocks to isolated minimum requirements alone.

Impact on businesses: compliance, costs, opportunities

Even under the current legal framework, businesses should check:

whether existing non-residential buildings with more than 20 parking spaces have had at least one charging point since 1 January 2025;
whether ongoing or planned new-build and renovation projects comply with the current GEIG requirements;
whether construction contracts, main contractor agreements and design contracts clearly address compliance with the GEIG (current and foreseeable future standards).

Violations may not only result in fines but can also lead to delays in building permit and acceptance processes and trigger warranty or liability issues internally.

In view of the planned tightening of regulations on 1 January 2027, a strategic approach is recommended:

Portfolio analysis: Identification of buildings with a relevant number of parking spaces, prioritisation by location, type of use and remaining lease terms.
Technology and operator strategy: Deciding whether the charging infrastructure should be operated in-house, by tenants or by a third-party operator (CPO).
Load management and energy integration: Using smart charging guidelines as an opportunity to optimise energy management (e.g. PV, storage, flexible loads) and reduce costs.
Contract drafting: Clarification of cost allocation and responsibilities in rental, lease, service and management contracts.

Transactions and due diligence

In the transaction environment, GEIG compliance is increasingly becoming a separate point of review:

Existing and foreseeable obligations (particularly from 2027 onwards) may lead to significant capital expenditure requirements and thus raise valuation issues.
Due diligence should analyse not only the current state of the charging infrastructure, but also the capacity of the electrical infrastructure and the owner’s planning.
Warranty and indemnity provisions in the purchase agreement should consider potential retrofitting obligations and the risk of fines.

Conclusion: Early action avoids costly retrofits

The amendment to the GEIG will significantly tighten the regulatory framework for charging infrastructure on buildings and present new challenges, particularly for companies with larger car parks. At the same time, forward-looking planning opens up opportunities to integrate charging infrastructure sensibly into mobility and energy concepts, thereby realising competitive advantages.

Companies would be well advised to closely monitor the legislative process, review existing and planned projects at an early stage, and develop tailored strategies in good time for the planning, financing, operation and contractual structuring of the charging infrastructure.

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