Search
Contact
03.11.2025 | KPMG Law Insights

CO₂ contracts for difference: Participation in the preliminary procedure is a prerequisite for funding

Companies can apply for funding in the preliminary procedure for the climate protection contracts program until 1 December 2025. The funding from the Federal Ministry for Economic Affairs and Energy (BMWE) is aimed at both traditional energy-intensive industries (including chemicals, paper, cement and glass) and small and medium-sized enterprises that want to convert their production processes to be climate-friendly. This is based on the model ofcarbon contracts for difference. Funding is provided for transformation projects that aim to use climate-friendly technologies such as renewable energies, hydrogen or carbon capture and storage (CCU/S).

The funding guideline has been significantly enhanced for the 2026 round and opened up to SMEs in particular. Participation in the preliminary procedure is a mandatory requirement in order to be able to submit a bid in 2026 and thus receive funding. Eligible companies should familiarize themselves with the new regulations at an early stage in order to secure competitive advantages.

What are CO₂ contracts for difference?

CO₂ contracts for difference are state subsidies from the BMWE. The aim is to incentivize energy-intensive companies to switch to climate-friendly technologies, which are currently still associated with high costs.

CO₂ contracts for difference guarantee a fixed CO₂ price over a period of 15 years. The state agrees a base price with the participating companies. If the market price is lower, the state pays the difference; if it is higher, the company is reimbursed. This is intended to create planning security, promote new technologies and strengthen the competitiveness of the industry.

In order to receive such funding, eligible companies must go through three phases: A preparatory procedure, the competitive bidding procedure and, after successful participation in phase 2, the grant relationship begins. Once the funding decision has been approved, the construction and trial operation of the subsidized system can begin. However, the CO₂ contract for difference only begins with the start of the subsequent operational business.

Adjusted funding conditions for 2026

Following the first funding round in 2024, the BMWE has revised and adapted the funding guidelines for 2026. The aim is to make the program more accessible and attractive for SMEs by reducing the minimum annual greenhouse gas emissions. In addition, companies should be able to react more flexibly to unforeseen events and developments, for example by allowing greater deviations from planned emission reductions.

There are several relevant changes with regard to technologies and energy sources: For example, the hurdles for the use of hydrogen have been lowered. In contrast to the first bidding process, technologies for capturing CO₂ for later storage or use (known as carbon capture utilization and storage) are also eligible for funding. Another change is that the production of industrial steam can now be subsidized under certain conditions.

Participation in the preliminary procedure for the 2026 bidding process now possible

Interested companies must participate in the ongoing preliminary procedure by December 1, 2025. To do so, they must submit a complete pre-application by the deadline using the forms provided. December 1, 2025 is a material cut-off date; pre-applications received after this date will no longer be considered. Participation in the preliminary procedure entitles companies to participate in the subsequent bidding procedure. Companies that have already participated in 2024 can take part in the 2026 preliminary procedure by submitting a simple declaration of confirmation.

In the preliminary procedure, companies will also be given the opportunity to ask questions about the bidding process. The bidding process is scheduled to start in mid-2026. It is currently still subject to budgetary approval and requires approval by the EU Commission under state aid law.

Conclusion

Companies should check now whether their transformation projects are eligible for funding, take part in the preliminary procedure and prepare specifically for the 2026 bidding process. Those who understand the funding mechanisms and take a strategic approach can not only secure financial support, but also strengthen their competitive position in the increasingly climate-neutral industrial sector.

 

Explore #more

21.11.2025 | In the media

KPMG Law Interview in Real Estate I Haufe: Substitute building materials: “Secondary is not second class”

The Substitute Building Materials Ordinance is intended to harmonize the circular economy in construction, but legal uncertainty and bureaucracy are holding it back. How can…

21.11.2025 | KPMG Law Insights

Residential construction turbo: more living space on existing properties

Since October 30, 2025, new regulations on the creation of living space have been in force in the German Building Code (BauGB). At the heart…

19.11.2025 | KPMG Law Insights

New Packaging Implementation Act tightens obligations for companies

With a new Packaging Implementation Act (VerpackDG), German law is to be adapted to the EU Packaging Regulation. The Federal Ministry for the Environment…

18.11.2025 | In the media

KPMG Law Statement in the FAZ on the subject of deepfakes

Fraudsters can easily falsify invoices or even act as company bosses. Companies can defend themselves against this, but there are no miracle weapons against AI…

17.11.2025 | KPMG Law Insights

Video surveillance in rental properties: What should landlords be aware of?

Video surveillance of rented properties is only possible under strict legal conditions. More and more owners want to keep an eye on and secure their…

13.11.2025 | KPMG Law Insights

Implementing AI in the legal department – these are the success factors

Artificial intelligence (AI) only benefits the legal department if it is implemented correctly. The technology promises to automate time-consuming routine work and fundamentally improve the…

13.11.2025 | KPMG Law Insights

First omnibus package to relax CSDDD, CSRD and EU taxonomy obligations

On November 13, 2025, the EU Parliament voted on its negotiating position regarding the so-called omnibus package, which provides for a relaxation of the CSRD,…

12.11.2025 | In the media

KPMG Law Statement in In-house Counsel: More stability under the umbrella of corporate governance

There is a lot of talk about “corporate governance” in the face of multiple crises and regulatory tendencies on the part of legislators. But what…

07.11.2025 | Deal Notifications

KPMG Law and KPMG advise Diehl Defence on the acquisition of the Tauber Group

KPMG Law Rechtsanwaltsgesellschaft mbH (KPMG Law) and KPMG AG Wirtschaftsprüfungsgesellschaft (KPMG) advised Diehl Defence on the acquisition of the Tauber Group. KPMG Law provided legal…

07.11.2025 | KPMG Law Insights

Changes to the H-1B visa and their consequences for US hiring and secondment practices

President Trump’s administration has introduced two significant changes to the highly popular H-1B visa program for skilled workers: The previous random lottery will be replaced…

Contact

Marc Goldberg

Partner

Tersteegenstraße 19-23
40474 Düsseldorf

Tel.: +49 211 4155597976
marcgoldberg@kpmg-law.de

Sina Glahn

Associate

Heidestraße 58
10557 Berlin

Tel.: +49 30 530 199 194
sglahn@kpmg-law.com

© 2024 KPMG Law Rechtsanwaltsgesellschaft mbH, associated with KPMG AG Wirtschaftsprüfungsgesellschaft, a public limited company under German law and a member of the global KPMG organisation of independent member firms affiliated with KPMG International Limited, a Private English Company Limited by Guarantee. All rights reserved. For more details on the structure of KPMG’s global organisation, please visit https://home.kpmg/governance.

 KPMG International does not provide services to clients. No member firm is authorised to bind or contract KPMG International or any other member firm to any third party, just as KPMG International is not authorised to bind or contract any other member firm.

Scroll