In its letter dated 31 March 2025, the Federal Ministry of Finance has made a 180° turn on its previous administrative practice concerning the operation of energy generation plants. In the case of decentralised consumption of electricity (so-called direct consumption), there is no (longer) a back and forth supply of electricity under VAT law between the operator of the energy generation plant (photovoltaic, biogas plants and cogeneration units) and the grid operator. In addition, the Federal Ministry of Finance has revised the use of heat, which is a contribution of goods without consideration, in CHP plants. Action is required by 1 January 2026.