The German Government has begun preparing legislation that would require operators of coal- and oil-fired power plants currently held in the grid reserve to keep fuel stocks and stand ready to generate electricity if a natural gas shortage is declared this winter, according to a draft law reported by Bloomberg on November 12.
Still under discussion within the government, the draft “law on keeping replacement power plants on standby” would allow these units to return temporarily to the regular electricity market only if the government formally declares a gas emergency or alarm stage — the two highest of the three crisis levels in Germany’s Gas Emergency Plan.
The German Government aims to replace gas-fired generation, freeing up remaining gas supplies for households and industry, which cannot easily switch fuels.
The measure is framed as a temporary addition to the existing Gas Emergency Plan and is intended to expire by March 31, 2028, without permanently returning the plants to the market.
Operators would be obliged to maintain readiness and stockpile fuel — enough coal for 30 days of full-load operation or enough oil for 10 days — according to the draft details reported by Handelsblatt and Berliner Zeitung. The same thresholds applied under the equivalent 2022 legislation.
The rules would cover plants already in the grid reserve (normally activated only to stabilise the electricity network) as well as units scheduled for closure in 2026 or 2027 under the coal phase-out.
Germany’s reserve fleet is estimated at more than 8 gigawatts (GW), with hard coal forming the largest share. The Federal Network Agency (Bundesnetzagentur) has set the grid reserve requirement for winter 2026-27 at 7.4 GW, of which 4.7 GW is to come from plants in Germany.
The draft notes that coal and oil are available at short notice and that their supply does not depend directly on crisis regions in the Middle East.
The proposal comes amid low gas storage levels and elevated prices linked to disruptions in the Middle East.
As of early November, German storage stood at around 61 per cent, missing the statutory November 1 target of 80 per cent for most facilities and 45 per cent for six of them — about 70 per cent overall. According to the storage operators’ association Initiative Energien Speichern (INES), it is the lowest level since comparable records began in 2011.
Storage has continued to decline and stood near 58 per cent by mid-November.
INES warned on November 10 that an extremely cold winter could produce supply shortfalls in early 2027, while supply is expected to hold under normal or mild conditions.
Economy minister Katherina Reiche of the Christian Democratic Union (CDU) has recently advanced a strategic national gas reserve for future winters. A draft bill from her ministry, circulated on October 13, puts its size at about 24 terawatt hours — roughly 10 per cent of German storage capacity — with build-up due to begin in 2027.
The coal-and-oil readiness plan is presented as a complementary short-term measure to bolster energy security.
Energy companies have previously called for greater use of reserve coal capacity to ease prices. In March, the government said it would review bringing reserve coal plants back to the market to curb electricity prices, Bloomberg reported.
Any large-scale activation would increase power-sector emissions, as coal is the most carbon-intensive generation source. Hard coal plants in the grid reserve emit about 1.6 times as much CO2 per unit of electricity as the average gas-fired plant, according to a 2022 assessment by the Öko-Institut.
The plan echoes temporary measures taken during the 2022 energy crisis triggered by reduced Russian pipeline supplies, when reserve plants were allowed back into the market under legislation in force from July 2022. Those rules expired on March 31, 2024.
The current draft remains classified as restricted and has not yet entered the formal legislative process.
The European Central Bank has kept interest rates on hold despite warning that the energy shock from the Iran war is still feeding through to eurozone prices. https://t.co/woIYKebM9F
— Brussels Signal (@brusselssignal) October 30, 2026
