---
title: No Manipulation Found in the German Power Market (Yet)
description: This week the German Federal Network Agency (BNetzA) and the German Federal Cartel Office (BKartA) published the results of their joint investigation into the German power market price spikes that occurred in November and December 2024.
image: https://www.regtrail.com/hubfs/Blog%2022-Oct.png
---
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# No Manipulation Found in the German Power Market (Yet)
RegTrail | 22 October, 2025
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**This week BNetzA, the German energy regulator, and the German Federal Cartel Office (BKartA) published (click [here](https://www.bundesnetzagentur.de/SharedDocs/Pressemitteilungen/EN/2025/20251021_Preisspitzen.html)) the conclusions of their joint investigation into the German power market price spikes that occurred over several days in November and December 2024.**
The price spikes occurred over five days from 5 to 7 November 2024 and 11 and 12 December 2024 during the so-called “dunkelflaute” (or “dark doldrums”), a highly appropriate term used to describe a phenomenon where wind and solar generation are low coinciding with periods of high electricity demand. Over the dates above, there was a cluster of expensive hours where prices peaked at EUR 936/MWh. Prices were also above EUR 300/MWh in 34 hours across the five days. The authorities considered the prices abnormal, even when compared to historical *dunkelflaute* periods.
The agencies performed their respective investigations from both an anti-trust perspective (i.e. whether certain large generators played a role in elevating prices) and from a market perspective, the latter examining whether REMIT rules had been violated and whether security of supply was at risk during these hours. The anti-trust investigation examined the possibility of capacity withholding – that is where generation capacity could have been sold at prices above the unit’s short-run marginal cost (SRMC). According to the report, under local anti-trust rules, capacity withholding must be accompanied by a market dominance element. As such, BKartA’s investigation focussed most heavily on the five large German generators (who are named on page two of the report) and aimed to address two questions. The first, whether these firms actually utilised the power plants that were reported as available, and the second, whether the power plants reported as wholly or partially unavailable were genuinely unavailable. SRMCs were expressly ignored in the investigation given the magnitude of the prices during these periods.
BKartA concluded that it did not find any evidence of capacity withholding but caveated this conclusion by citing the significant challenges associated with performing a comprehensive, market-wide investigation. The REMIT investigation, in assessing the security of supply risk, focused on the utilisation rates of dispatchable power plant capacities available for the German market area in November and December 2024. These analyses showed that the utilisation of dispatchable capacity was significantly higher than reported in the media shortly following the event. For example, during the most expensive hours on 6 November and 12 December between 5pm and 6pm, the report concluded that 4.5 GW and 3.4 GW of capacity respectively was still available (see graphic below). The report notes that lignite and coal-fired power plants were reported as available under REMIT and were used extensively during the expensive hours on 6 November and 12 December. The report concluded that security of supply was guaranteed at all times (the report also attempts to explain the gap between the much-publicised capacity shortages and the “official” numbers).
On the trading side, the BNetzA also examined the bidding behaviour of market participants with regard to possible market manipulation under REMIT. The investigation focussed on which parties had benefited directly or indirectly from the high prices and whether there were any noticeable anomalies in bidding behaviour. The report notes that bidders did not bid purely on the basis of marginal costs during the relevant periods, but this factor alone does not mean they had violated REMIT. A REMIT violation would only have arisen if the circumstances of the individual case indicated that market participants had taken “targeted measures” to bring about artificial price levels (such measures are not elaborated on any further). BNetzA concluded that no violations had been identified “to date” but ominously added that there were still individual cases under “in-depth” investigation which presumably have the potential to contradict its interim conclusion.
The report concludes that given *dunkelflaute* will continue occurring in the future, urgent legislative measures are needed for the expansion of dispatchable capacity in Germany, as is the need for more flexibility on both the demand and generation sides. The report concludes by pointing out that data availability must also be improved, specifically TSO data and data relating to generation availability.
**The six-page report (which may be found** [**here**](https://www.bundesnetzagentur.de/DE/Fachthemen/ElektrizitaetundGas/Aktuelles/Strompreis/Preisspitzen_Untersuchung.pdf?__blob=publicationFile&v=1))**leaves several open questions regarding the ongoing investigations. It remains unclear however if major subsequent enforcement actions are likely to emerge after the regulators have ostensibly signalled a** *soft* **all-clear. At a broader level, the topic of generation withholding has proven to be a popular theme in 2025. In July ARERA, the Italian energy market regulator, also published a market study into suspected economic withholding in the Italian power generation market (click** [**here**](https://www.arera.it/fileadmin/allegati/docs/25/302-2025-R-eel-ALLEGATO_A.pdf)**) which has led to one publicised enforcement action so far (click** [**here**](https://www.arera.it/atti-e-provvedimenti/dettaglio/14-25dsai)**).**
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