Radio meter obligation 2027: what must be done by 31 December 2026

The amendment to the Heating Costs Ordinance that entered into force on 1 December 2021 changed how consumption is metered in Germany. For most buildings, this is only becoming visible now: at the turn of the year 2026/2027, the transitional period for existing devices expires. Anyone who has not acted by then will be recording their consumption from January 2027 with devices that no longer comply with the ordinance.

This article puts the deadlines into context, sets out the actual consequences of missing the deadline and shows which decisions an owners’ association now has to make.

What the Heating Costs Ordinance requires from 1 January 2027

The core is set out in § 5 of the Heating Costs Ordinance. Consumption metering equipment must be remotely readable. Remotely readable means that the values can be read without access to the individual flat — the traditional meter-reading appointment is no longer needed.

The ordinance works with three key dates that are regularly confused:

The last key date gives rise to the much-cited “radio meter obligation 2027”: from 1 January 2027, there is no longer any transitional period. It affects heat cost allocators, heat meters and hot water meters. Cold water meters do not fall under the Heating Costs Ordinance; they are subject to the law on measurement and calibration (Mess- und Eichrecht) and, where installed, the Metering Point Operation Act (Messstellenbetriebsgesetz).

Interoperability is the real lever

Remote readability alone says little. What matters is that the devices output their data in a format that not only their own manufacturer can read. That is exactly what the requirement for interoperability and connectability to a smart meter gateway means.

In practice, this is the point at which associations have been getting stuck for years: radio devices were installed, but the data lies exclusively with the installing metering service. A change of provider then fails not because of the technology, but because of the refusal to hand over the data. The ordinance addresses this explicitly — it wants open systems, not merely radio.

Anyone commissioning a retrofit should therefore have interoperability guaranteed in writing, including a commitment to hand over the consumption data in an open format when the contract ends.

Who is obliged

The obligation is addressed to the building owner. For owners’ associations, this means: the association of flat owners bears the obligation and passes the necessary resolution. The property management prepares, obtains quotes and implements; however, it does not decide alone.

Landlords of individual flats in a WEG are indirectly affected: they bill their tenants on the basis of the values that the association has recorded.

The ongoing costs are recoverable. § 7 Abs. 2 HeizkostenV and § 2 of the Operating Costs Ordinance (Betriebskostenverordnung, BetrKV) expressly name the costs of consumption metering, reading and billing, including the rental of the equipment. The purchase of devices, on the other hand, is not an operating cost item — it must be financed from the maintenance reserve or through a special levy.

What happens if the deadline passes

A lot of pressure is being built up in the market here that is not objectively justified. Four points for context:

The Heating Costs Ordinance does not provide for a fine. Anyone who has not yet retrofitted on 1 January 2027 will not receive a notice or be set a deadline.

The 15 per cent does not apply here. The well-known 15 per cent reduction right under § 12 Abs. 1 HeizkostenV relates to billing that is not based on consumption. With devices that are not remotely readable, billing based on consumption is still possible — so this higher reduction right does not arise merely from the lack of remote readability.

What takes effect is the three per cent reduction. If, contrary to § 5 Abs. 2 or 3 HeizkostenV, remotely readable equipment is not installed, users may reduce their share of the heating costs by three per cent (§ 12 Abs. 1 Satz 2 HeizkostenV). The same reduction applies if, after the conversion, the monthly consumption information under § 6a HeizkostenV is not provided. Over the years and across all units, this adds up.

Of most practical relevance is the fourth point: a property management that does not inform the association of the deadline in good time and verifiably risks its own liability. The notice belongs in the invitation to the owners’ meeting and in the minutes — regardless of how the association subsequently decides.

Are there exceptions

The ordinance permits exceptions, but only in individual cases where retrofitting is technically impossible or economically unreasonable. This exception is to be interpreted narrowly. It applies, for example, where a radio connection cannot be established for structural reasons, but not where the association simply wants to avoid the investment.

Anyone relying on it should document the reasons for the specific building. A resolution “to waive retrofitting” does not constitute a valid ground for an exception.

The trap: retrofitting extends the commitment

The economically most consequential aspect of the deadline is rarely discussed openly. If the retrofit is commissioned from the existing metering service, a separate device rental contract usually begins for the new devices — terms of ten years are common. The association therefore fulfils an obligation from 2026 and in doing so ties itself in until the mid-2030s.

To make matters worse, the device and billing contracts are linked at many providers. Anyone who rents the devices obtains the billing from the same company — and can in practice no longer negotiate the price of billing.

That is why the question of provider belongs before retrofitting, not afterwards. An association that has its devices retrofitted by its current provider shortly before the deadline and then realises that it would like to switch metering service has given up its room for manoeuvre for a decade.

What owners’ associations should do now

The timetable is tighter than it appears. Between the meeting resolution, notice periods and installation appointments, twelve months can quickly pass.

1. Take stock. Which devices are installed, are they remotely readable, are they interoperable? The metering service must provide information about this.
2. Check the contracts. Term, notice period and whether the device and billing contracts are linked. Notice periods of twelve months to the end of the term are common.
3. Obtain quotes. At least two quotes are advisable, broken down separately into devices, reading, billing and consumption information. Only separate items are comparable.
4. Pass a resolution. The resolution should state a maximum amount per unit and authorise the property management to conclude the contract within this cap. A blanket resolution without maximum values is not sufficiently specific and can therefore be challenged.

If your property has not been converted yet, do not wait for the next ordinary meeting: the property manager can call an extraordinary meeting or initiate a written resolution, which all owners must approve in text form (§ 23 Abs. 3 WEG). If the deadline is missed, the retrofit remains mandatory — and users may reduce their share of the costs by 3 per cent (§ 12 Abs. 1 HeizkostenV).