Changing conditions in the natural gas market call for action to prepare for winter

FNB Gas welcomes the national gas reserve already initiated by the federal government as an important contribution to crisis preparedness and advocates for a supplementary supplier obligation to ensure market-based winter preparedness. Together with the Initiative for Energy Storage (INES), FNB Gas has submitted a discussion paper on this topic, highlighting the need for a clearly defined level of supply security through gas volumes in storage facilities.

Berlin, November 1, 2026. Germany’s security of supply depends on the interplay between efficient transmission networks and adequately filled storage facilities. German natural gas storage facilities are currently only 61.6 percent full, which is significantly below the legal requirement of an average of approximately 71 percent as of November 1. Current storage levels mark a historic low for this time of year. For FNB Gas, trends over the past few years show that not only crisis preparedness but also market-based winter preparedness must be adapted to the changing conditions of the natural gas market.

The national gas reserve is intended to ensure that, in exceptional crisis situations caused by external shocks—such as the failure of key import infrastructure—sufficient quantities of gas are available and grid stability can be maintained. The goal of a supplier obligation is to supplement this by securing the withdrawal capacity necessary for supply through the end of winter. A supplier obligation would place the responsibility for market-based winter preparedness on a broad basis. Balancing group managers would be required to hold defined volumes of gas in storage facilities as of February 1 of each year, but would remain largely flexible in managing their storage facilities and portfolios. Since the model can build on existing processes and systems, the administrative burden for implementing and monitoring the obligation remains low.

In their joint position paper, FNB Gas and INES analyze the changing conditions in the German gas market and the role of storage facilities in a mixed supply system consisting of pipelines and LNG terminals. The key finding: Available imports from Norway, the Netherlands, Belgium, and via LNG terminals can collectively provide only about 3 TWh per day. On very cold winter days, however, gas demand in Germany can reach up to 6 TWh per day. The remaining daily volume must be covered by storage facilities. It is particularly crucial that storage facilities are sufficiently filled by the end of winter to provide the necessary withdrawal capacity, ensuring that regular customer supply can be maintained at all times. As storage levels decline, the technically available withdrawal capacity decreases continuously.

FNB Gas had already pointed out this trend in its 2026 report on supply security and proposed further developing supply security measures with concrete plans. The current situation confirms the analysis presented at that time.

“The federal government has already taken an important step toward strengthening crisis preparedness with the gas reserve. We expressly welcome this. However, given the new market regulations, this instrument is not sufficient to adapt winter preparedness to the changed situation on the gas market. The supplier obligation is a sensible complement to the reserve, particularly to ensure the withdrawal capacity from storage facilities required at the end of winter,”explains Dr. Matthias Jenn, CEO of FNB Gas. “Without such an additional market-based instrument, we will face exactly the same situation a year from now with regard to low storage levels—the very situation that is posing challenges for us this winter,” Jenn concluded.