EnBW Energie Baden-Württemberg AG

Europe currently faces extreme geopolitical uncertainty, making energy security, decarbonisation, and lower energy costs top priorities to secure energy supply for its citizens & industry & restoring its competitiveness. Achieving these goals will require a massive expansion of renewable energy & the modernization of electricity grids, demanding hundreds of bn. of Euros in investment.

As an early adopter of sustainability reporting and voluntary ESRS alignment, EnBW welcomes the revision of the European Sustainability Reporting Standards (ESRS). However, we emphasise that the key priority must be long-term stability and legal certainty, ensuring that remaining inconsistencies are addressed comprehensively now in order to avoid uncertainties in the future.

In the view of EnBW Energie Baden-Württemberg AG, the European Commission’s legislative proposal on Artificial Intelligence (AI) has drawn up a regulation which offers opportunities. At first sight, this is our first brief feedback from an energy point of view and the operation of critical infrastructure. On the last page of the attached document, an overview of AI Use-Cases can be found in a risk spectrum.

Filed in German · English published by the European Commission

As EnBW Energie Baden-Württemberg AG we welcome the approach of European Commission to conduct an Impact Assessment concerning ethical and legal requirements for AI. For several years already we have developed AI solutions in the energy sector. As operator and service provider in the field of critical infrastructures, we at EnBW operate multiple self-developed AI services already productively.

Decarbonisation of the transport sector: An urgent mandate for the EU to act The transport sector remains one of the main challenges on the path to climate neutrality in the European Union. Despite ambitious targets under the European Green Deal, emissions in this sector have not yet been sufficiently reduced.

Filed in German · English published by the European Commission

We broadly support the EU Taxonomy framework for the energy sector and consider the existing technical screening criteria largely appropriate. We particularly welcome the simplifications introduced in July 2025 and the recent amendments in the Climate Delegated Act, notably with regard to life-cycle emissions for geothermal energy.

Netze BW GmbH is the largest DSO within the EnBW Group with over 5,000 employees. It operates the distribution grid in large parts of Baden-Württemberg (southwest of Germany) for the electricity and gas sectors. Approx. 4,800 MW of installed capacity has already been connected to the distribution grid of Netze BW GmbH so far.

EnBW welcomes the proposals for the revision of the CSR Directive published by the EU Commission on 21 April 2021. We support the goal of increasing transparency with regard to sustainable aspects and thus meeting the growing demand for sustainability-related information to an even greater extent.

For input: CO2 standards for cars and vans - revision (Roadmap) EnBW Energie Baden-Württemberg AG fully supports the 2050 decarbonization target of the European Union and the European Commission’s amendment of the Regulation setting CO2 emission standards for cars and vans.

As EnBW, we very much welcome that large parts of the proposals of the Directive and Regula-tion on the internal gas market for the establishment of a hydrogen market, correspond to the model of the existing and functioning internal gas market. However, we see some points in the draft that could considerably delay the rapid development of a hydrogen market.

General observations EnBW Energie Baden-Württemberg AG shares the vision of a climate neutral energy system and supports the objective of EU-climate neutrality. Renewable and decarbonized gases like biomethane and hydrogen will have to play a key role to reach this objective. For this reason, EnBW is engaged in the EU Clean Hy-drogen Alliance, working on projects along the gas value chain.

EnBW Energie Baden-Württemberg AG supports the revision of Directive 2014/94/EU on the Deployment of Alternative Fuel Infrastructure to encourage the use of low- and zero-emission vehicles. To successfully contribute to the European Green Deal, we suggest the revision to highlight the following aspects: 1.

As one of the largest operators of energy facilities in Germany and through its shareholdings also owner of grids in the electricity and gas sectors, EnBW Energie Baden-Württemberg AG considers the following points to be important as feedback on the legislative proposal to reduce methane emissions (ME) in the energy sector.

EnBW is one of Germanys largest utilities (30.000 employees, 50 billion investments in the energy transition until 2030) and active physical producer and marketer of biogas and biomethane in the EU. We highly appreciate the Commissions continued efforts to strengthen the sustainability framework for renewable fuels. Please find our analysis and feedback in the attached file.

Design of the guide: In the view of the EnBW, the guide should not be sufficiently detailed in terms of bureaucracy to delay transposition in the Member States. It should therefore not stand in the way of detailed rules, which are already in the process of being implemented, which are already in the process of being implemented. The most important is the rapid designation of areas and the acceleration of permits.

Filed in German · English published by the European Commission

At EnBW, we are actively transforming infrastructure to support data centre development and related services. Decommissioned power plant sites within our portfolio are particularly well suited for this purpose, as they already provide ample space, reliable water access for cooling, and, crucially, strong grid connections at scale.

EnBW AG (Energie Baden-Württemberg AG) is part of the ongoing research project "ChaNGe (Inductive Charging - Next Generation)", funded by the German government. One of the goals of this project is to measure the losses to enable public charging with billing for wireless charging, from which we expect a market breakthrough soon.

We strongly endorse this initiative that supports the Green Deal and helps to ensure that vehicles on EU roads are clean not only during the initial assessment but over their entire lifetime at any typical usage.

With the UmwRG, which was extensively amended in 2017, Germany has all the directives in nat. Law implemented. Calls for the correct implementation of EU secondary legislation to be ensured (paragraphs 31 and 32) and for a review of the national legislation. Legislation by the Member States themselves (paragraph 36) is therefore sufficient.

Filed in German · English published by the European Commission

We represent a European asset-backed energy trading firm, active on the wholesale energy markets predominantly to hedge our risks arising from our commercial business (e.g. power generation, retail business). We are therefore an active participant also in the commodity derivatives markets and thus subject to a wide range of financial market laws and regulations, including MIFID and EMIR among others.

EnBW Energie Baden-Württemberg AG welcomes the opportunity to comment on the draft REMIT II Implementing Regulation. While we fully support efforts to strengthen market transparency and integrity, we are concerned that the current draft of the IR will increase burden on market participants without real benefit on market functioning and integrity.

EnBW welcomes the European Commissions draft delegated act under Article 25 of the Net-Zero Industry Act (NZIA), particularly for its balanced and feasible approach to integrating sustainability criteria into public procurement for net-zero technologies. With regard to the listed requirements for PV in Article 2 there are no objections.