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Wind farm near the German North Sea coast
Germany's open-ended real estate funds can now allocate up to 15% of assets to renewable energy infrastructure following final approval of the Location Promotion Act (StoFöG) by the Federal Council on January 30th. The change removes tax and supervisory barriers that blocked such investments. Industry estimates suggest the shift could mobilise double-digit billions.
The law permits direct investment in electricity and heat generation, conversion, transport and storage from renewables. Crucially, investments no longer require structural connection to buildings. Standalone solar parks, onshore and offshore wind farms, photovoltaic installations and charging infrastructure all qualify. Rooftop systems and direct operation are also permitted.
Thomas Lehmann, Director at consultants Wüest Partner, called it "a strategic paradigm shift, not a technical detail." The opportunity, he argues, is portfolio quality: stable real estate cashflows combined with higher-yield energy infrastructure, measurable carbon reduction, and improved property appeal through tenant electricity supply.
Commerz Real plans immediate deployment. Mario Schüttauf, fund manager of its Hausinvest fund, confirmed the firm will add solar parks, photovoltaic systems and wind farms alongside existing holdings. Medium-term goal: supply properties directly with electricity, offering power to tenants at favourable rates to improve occupancy and valuations.
Commerz Real already operates renewables through its Klimavest and Infravest funds, giving it execution capability other managers may lack. Initial reports suggest not all major fund houses share the enthusiasm. The regulatory freedom is new; the operational complexity is not.
ZIA President Iris Schöberl welcomed the passage after three years of delays. She expects "a surge in investment in renewable energies" contributing to Germany's energy transition. Tax experts at Hansainvest called the clarification around asset management versus commercial activity critical. Long-term lending and infrastructure investments are now permissible without jeopardising fund tax status.
For Germany's open-ended fund market, the law creates a new allocation category with regulatory clarity. Whether managers treat the 15% threshold as a strategic opportunity or marginal allocation will determine how much capital moves. Commerz Real's positioning suggests they view renewables infrastructure as a competitive advantage, not compliance. How quickly others follow will show whether this becomes a genuine portfolio component or a niche play.