Bundesnetzagentur and Bundeskartellamt publish study of electricity price peaks during “dunkelflaute” periods in 2024
Year of issue 2025
Date of issue 2025.10.21
The Bundesnetzagentur and Bundeskartellamt have closely examined the unusually high electricity wholesale prices in November and December 2024 during the periods of extremely low wind and solar generation known as “dunkelflaute”. Their investigations have not revealed any potentially abusive practices.
“During the dunkelflaute periods, almost all of the controllable power plant fleet was put to use. At the same time, a secure electricity supply was constantly guaranteed by reserves. We have not found any signs of market manipulation so far. There are still some matters that we need to look into further. For future dunkelflaute periods, we continue to see an urgent need for new, controllable capacity and much greater flexibility of supply and demand
,” said Klaus Müller, President of the Bundesnetzagentur.
Andreas Mundt, President of the Bundeskartellamt, said, “Our investigations have not uncovered any indications of generating capacity being withheld in an abusive manner by any of the five largest electricity producers during the two phases of dunkelflaute at the end of 2024. The high prices during this period were not the result of anti-competitive behaviour. However, it is clear that excessive prices can be much more effectively prevented by functioning competition than by the control of abusive practices, no matter how strict. That is why it is so important to use the upcoming tenders for new controllable capacity to reduce the high level of market concentration in the electricity generation marke
t.”
The investigations were triggered by unusually high short-term electricity wholesale prices. From 5 to 7 November and from 11 to 12 December, during the dunkelflaute periods, the prices per megawatt hour rose to over €300 for a time and peaked at over €900. The average price per megawatt hour in 2024 was about €79.
Bundeskartellamt results
The Bundeskartellamt is responsible for looking into possible breaches of competition law. The prohibition of anti-competitive abusive practices is intended to prevent electricity producers with a dominant position in the market from driving up electricity generation prices in an abusive manner. As only major electricity producers can have market dominance, the Bundeskartellamt undertook in-depth examinations of the use of power plants by the five largest companies: EnBW, LEAG, RWE, Uniper and Vattenfall. It examined whether power stations reported to be available were actually used and whether power stations where the capacity was reported as not available, or partially not available, were indeed unavailable. If a dominant undertaking had not used electricity generating capacity even though it was available and could have been used profitably, with the aim of pushing up prices, it would be an indication that the undertaking was withholding capacity in a manner prohibited under competition law. The power plant deployment planning data collected for power plants with a capacity of over 10 MW show that nearly all the market capacity registered as available generated electricity during the relevant periods. The free capacity of the generating capacity registered as available and not used amounted to an average of about 170 MW from the five big producers from 5pm to 7pm on 6 November 2024 and about 410 MW from 4pm to 6pm on 12 December 2024. This remaining capacity is mostly highly flexible storage facilities or more flexible power stations with particularly high marginal costs whose marketing is less based on day-ahead prices and more on intraday ones, which in some cases were considerably lower. The Bundeskartellamt also examined the reasons why individual unused power stations were not available, for example due to breakdowns, priority heat generation or balancing reserves contracts.
These investigations and analyses did not show any abusive withholding of capacity for the relevant time period.
Bundesnetzagentur results
The Bundesnetzagentur carried out analyses to assess the security of supply and with a view to identifying possible breaches of the prohibitions against market abuse in REMIT (Regulation (EU) No 1227/2011). The analyses of the generation data revealed that the controllable power plant capacity was used on a much greater scale than the data published immediately after the event initially suggested. The lignite and hard coal-fired power plants that could be used for general electricity generation and were registered as available were fully used in the expensive hours on 6 November and 12 December 2024, while there was remaining capacity available in natural gas and pumped storage power stations. The proportion of controllable power plant capacity available on the market but not used was thus much less than first assumed. In the most expensive hours of 6 November 2024 and 12 December 2024 – in both cases, from 5pm to 6pm – there were still about 4.5 GW and 3.4 GW respectively of remaining market capacity, according to estimates by the Bundesnetzagentur. There were also about 12 to 13 GW of reserves and balancing energy, so the electricity supply was secure during the whole period.
On the trading side, the Bundesnetzagentur examined market participants’ bidding behaviour with a view to identifying possible market manipulation under REMIT. It has so far found no evidence of a breach. There are some matters that the Bundesnetzagentur is still looking into in more detail.
Dunkelflaute periods such as those that occurred in November and December 2024 will happen again in future. The Bundesnetzagentur continues to believe that legislative measures to add controllable capacity are urgently needed to keep sufficient generating capacity available in the long term. There is also a general need to increase flexibility, both in demand and generation, for example by more flexible operations to leverage biomass capacity hitherto unused on the market.
Background
Short-term electricity wholesale prices sometimes fluctuate strongly throughout the day and during the year. They do so because the supply of electricity needs to match demand exactly at all times and the two variables fluctuate independently of each other over time. In November and December 2024, there were times with very little wind and sun, leading to a very low supply of renewable energy. A sustained meteorological period with low levels of sunlight and wind is known as a dunkelflaute. At these times, electricity is largely supplied by more expensive, controllable power plant capacity, which can, when demand is high, lead to higher prices.
The two authorities collected and evaluated large data sets from public and non-public sources on the fundamental situation, the use and availability of power plants and the trading behaviour. A summary of the analysis results may be accessed here: www.bundesnetzagentur.de/1076630.