Key Facts About the HKVO Deadline at a Glance
The revised German Heating Cost Ordinance (Heizkostenverordnung, HKVO), which has been in effect since December 1, 2021, transposes the EU Energy Efficiency Directive (EED) into German law. One of the central requirements: All metering devices for recording heat and hot water consumption must be remotely readable by December 31, 2026 at the latest. From January 1, 2027, only meters and heat cost allocators that can be read without entering the apartment may be operated in Germany.
This legal obligation applies to all buildings with central heating and hot water supply serving two or more residential units — and thus to the vast majority of properties we manage through our HOA management and rental management services.
Affected by the obligation:
Exempt:
Timeline of the Heating Cost Ordinance: All Deadlines at a Glance
The upgrade is being implemented in several stages. The following timeline shows the key milestones:
| Date | Legal Obligation | Legal Basis |
|---|---|---|
| Since December 1, 2021 | New installations exclusively with remotely readable devices | Section 5(2) HKVO |
| Since January 1, 2022 | Monthly consumption information where smart meters already exist | Section 6a HKVO |
| Since December 1, 2022 | New devices must additionally be interoperable and Smart Meter Gateway compatible | Section 5(5) HKVO |
| By December 31, 2026 | All existing devices must be retrofitted or replaced | Section 5(3) HKVO |
| By December 31, 2031 | Already installed remotely readable devices must be interoperable | Section 5(4) HKVO |
With less than twelve months until the deadline expires, a recent VDIV survey shows: approximately 58 percent of homeowner associations and 61 percent of rental properties have already been upgraded. This means conversely: Around 40 percent of buildings still need to act before the end of the year.
Which Metering Devices Must Be Remotely Readable?
The HKVO obligation for remote readability applies to all devices used for consumption-based recording of heating and water costs.
Heat Cost Allocators
Heat cost allocators record the relative heat consumption at individual radiators. The widely used evaporation tubes do not meet HKVO requirements and must be replaced with electronic radio-based allocators. Modern heat cost allocators with a two-sensor system measure both the radiator temperature and the room temperature and automatically transmit the values via radio.
Heat Meters
Heat meters are used for underfloor heating, central heating with apartment stations, or larger systems. They measure actual heat consumption in kWh. These devices must also be remotely readable by the end of 2026. For new installations or replacements after the calibration period expires (typically 5 years), only radio-capable meters may be installed since December 2021.
Hot Water Meters
Hot water meters record the consumption of centrally heated water. The calibration period is 6 years. Here too: remote readability must be ensured by December 31, 2026 at the latest.
Special Case: Cold Water Meters
The HKVO only covers the recording of heat and hot water. The obligation to install cold water meters is not uniformly regulated at the federal level but is a matter for individual German states. In Hesse, the state building code requires the installation of cold water meters in new buildings. There is no nationwide HKVO obligation for remote readability of cold water meters — however, for practical reasons, a uniform upgrade of all meters in a building is recommended.
What Does "Remotely Readable" Mean Under Section 5 HKVO?
Under Section 5(2) Sentence 2 HKVO, a metering device is remotely readable if it can be read without access to the individual unit. In practice, this means: the meter reader no longer needs to ring the doorbell and enter the apartment — consumption data is transmitted via radio.
Walk-by and Drive-by Methods
In these methods, a metering service employee collects the data using a mobile receiving device:
Both methods meet the HKVO requirements for remote readability.
Gateway Solution with Smart Meter
The most technically advanced solution is a central radio gateway in the building that automatically collects all consumption data and transmits it to the metering service provider. In combination with a Smart Meter Gateway (SMGW), data can be transmitted in encrypted form and precisely on the billing date.
Since December 1, 2022, newly installed devices must be SMGW-compatible — they must meet the technical requirements for future connection to a Smart Meter Gateway.
Interoperability: Why It Matters
Interoperability means: the meters use an open standard and can be read by different metering service providers — not just the original supplier. This strengthens competition, facilitates switching service providers, and prevents proprietary isolated solutions.
Since December 1, 2022, interoperability is mandatory for newly installed devices. For existing devices, a transition period until the end of 2031 applies.
Consequences of Non-Compliance: Reduction Rights Under Section 12 HKVO
The Heating Cost Ordinance provides for specific sanctions in case of violations. Users — i.e., tenants or apartment owners — may reduce their share of heating costs.
3% Reduction for Missing Remote Reading
Under Section 12(1) Sentence 2 HKVO, the user may reduce their cost share by 3 percent if the building owner has failed to install remotely readable equipment contrary to Section 5(2) or (3).
3% Reduction for Missing Consumption Information
A further reduction of 3 percent is possible if the monthly consumption information required under Section 6a is not provided or is incomplete (Section 12(1) Sentence 3 HKVO).
15% Reduction Without Consumption-Based Billing
If, contrary to the HKVO, no consumption-based billing is carried out at all, the reduction right amounts to 15 percent of the consumption-independent portion (Section 12(1) Sentence 1 HKVO).
Cumulative Reduction Rights: Up to 21%
If multiple obligations are violated, the reduction rights can be cumulative. In the worst case — no remotely readable metering technology, no monthly information, no consumption-based billing — reductions of up to 21 percent are possible.
Important for HOAs: The reduction rights under Section 12 HKVO do not apply in the relationship between individual apartment owners and the homeowner association. However, they are highly relevant for rented condominiums — here, the tenant can reduce their costs vis-a-vis the landlord-owner.
Monthly Consumption Information (UVI) Under Section 6a HKVO
With the upgrade to remotely readable metering technology, an additional obligation arises: landlords must provide their tenants with monthly information about their energy consumption. This so-called monthly consumption information (UVI — unterjahrige Verbrauchsinformation) is intended to create transparency and motivate energy-saving behavior.
Content of Monthly Consumption Information
The UVI must contain at least the following information under Section 6a(2) HKVO:
Delivery: Email, App, or Portal
The information must reach the user directly — without them having to search for it. Permissible delivery methods include:
Most metering service providers offer digital portals or apps through which both the UVI and the annual billing can be provided.
Data Protection in Consumption Recording
Under Section 6b HKVO, consumption data may only be collected and processed for the legally prescribed purposes. Access is restricted to authorized persons (owners, property managers, metering service providers). Transmission must be encrypted, and portals must be secured with appropriate authentication mechanisms.
Recommended Action Plan for Owners and Property Managers
The December 31, 2026 deadline is approaching fast. Owners and property managers should proceed in a structured manner now:
Step 1: Conduct an Inventory Assessment
First, clarify: Which metering devices are already remotely readable? Which still need to be replaced or retrofitted? For unit management of individual apartments, it is also important to check whether the HOA has already upgraded or whether individual action is needed.
Inventory assessment checklist:
Step 2: Obtain and Compare Quotes
Demand for metering services typically surges toward the end of the year. Acting now avoids bottlenecks and allows for price comparisons.
Selection criteria:
Step 3: Pass an HOA Resolution (Simple Majority)
For homeowner associations: upgrading to remotely readable metering devices constitutes proper management under Section 19(2) No. 2 WEG (German Condominium Act). It can therefore be approved by simple majority at the owners' meeting — a qualified majority is not required.
As your HOA management, we prepare the corresponding resolution proposals and coordinate implementation. Ideally, the topic should be addressed at the next owners' meeting. If necessary, a written resolution procedure can also be used.
Step 4: Inform Tenants and Coordinate Appointments
Landlords should inform their tenants early about the planned upgrade. Installing new meters typically requires brief access to the apartment. Timely notification ensures smooth operations and fulfills information obligations under the GDPR.
Upgrade Costs: Purchase vs. Lease
The costs of upgrading vary depending on the type of device, provider, and chosen model (purchase or lease).
Acquisition Costs by Device Type
| Device type | Purchase price | Installation | Total approx. |
|---|---|---|---|
| Heat cost allocator (radio) | 40–60 euros | included or 30–50 euros | 50–110 euros |
| Hot water meter (radio) | 40–110 euros | 50–120 euros | 90–230 euros |
| Heat meter | 100–200 euros | 50–150 euros | 150–350 euros |
In addition, there are ongoing costs for reading, billing, and UVI provision of approximately 5–15 euros per device per year.
Allocability of Costs
If meters are purchased:
If meters are leased:
Many metering service providers offer full-service packages that include devices, installation, maintenance, reading, and billing — typically between 100 and 180 euros per residential unit per year.
Rent Increase Under Section 559 BGB
If the remotely readable meters are purchased and permanently installed, this constitutes a modernization measure within the meaning of Section 555b BGB. In this case, the landlord may increase the annual rent by up to 8 percent of the investment costs attributable to the apartment.
The prerequisite is a formal and timely modernization announcement at least 3 months before the start of the measure.
Exceptions and Hardship Cases Under Section 5(3) HKVO
The HKVO provides limited exceptions to the upgrade obligation. Under Section 5(3) Sentence 2 HKVO, an upgrade may be waived if:
In practice, however, these exceptions are interpreted narrowly. With modern systems, even older buildings can usually be retrofitted without problems. Anyone wishing to invoke an exception should document this thoroughly and seek legal advice if in doubt.
No exception applies simply because metering devices are still within their calibration period. The HKVO expressly requires that even functional legacy devices must be replaced by the end of 2026.
Benefits of Switching to Radio-Based Metering Technology
The legal obligation also brings practical benefits — for landlords, property managers, and residents alike:
No apartment access required: Tenants no longer need to be home when the meter reader comes. Scheduling issues and complex coordination are eliminated.
Automatic consumption information: Remotely readable systems enable the monthly transmission of consumption data. This promotes energy awareness and can lead to savings.
Faster, error-free billing: Digital data transmission reduces transcription errors and significantly accelerates the preparation of heating cost bills. As a digital property management company, we rely on fully digital processes — from consumption recording to billing.
Early detection of defects: Modern radio meters automatically report irregularities — such as a sudden spike in consumption due to a leak or a radiator malfunction.
Foundation for smart building applications: The radio infrastructure is a prerequisite for future digitization projects in the building and can be linked with electricity meters, building automation, and energy management systems.
Frequently Asked Questions About the Remote Reading Obligation (FAQ)
By when must all meters be remotely readable?
Under Section 5(3) HKVO, all non-remotely-readable metering devices for heat and hot water consumption must be retrofitted or replaced with remotely readable devices by December 31, 2026. From January 1, 2027, only remotely readable meters may be operated.
What happens if the deadline is not met?
If remotely readable equipment is not installed, tenants may reduce their heating cost share by 3% under Section 12 HKVO. If monthly consumption information is also missing, an additional 3% applies. Without consumption-based billing at all, a 15% reduction is possible — theoretically totaling up to 21%.
Who bears the costs of upgrading?
If meters are purchased, the landlord bears the acquisition costs. A rent increase under Section 559 BGB is possible (max. 8% of investment costs per year). If meters are leased, the ongoing costs are allocable as operating costs.
What resolution is required in an HOA?
The upgrade constitutes proper management under Section 19(2) No. 2 WEG and can be approved by simple majority.
Do cold water meters also need to be remotely readable?
The HKVO only covers heat and hot water. There is no nationwide obligation for remote reading of cold water meters. However, a uniform upgrade is recommended for practical reasons.
What does interoperability mean?
Interoperable devices can be read by different metering service providers — not just the original supplier. This facilitates switching providers and prevents vendor lock-in.
Does the monthly information obligation also apply to HOA owners?
The UVI obligation applies to tenants. In a pure HOA relationship (owner to association), there is no legal obligation for monthly information, though there is a practical interest in transparency.
Conclusion: Act Now Before Time Runs Out
The December 31, 2026 deadline is firm — and it cannot be postponed. Owners and property managers who act now not only avoid legal risks and reductions in heating cost bills but also benefit from better conditions and availability from metering service providers.
Our recommendation: Put this topic on your agenda this quarter. Conduct an inventory assessment, obtain quotes, and — if necessary — prepare the HOA resolution.
As your property management in the Rhine-Main area, we support you with the inventory assessment, obtaining quotes, and preparing the corresponding HOA resolutions. We are also happy to coordinate with metering service providers and inform tenants on your behalf.
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*As of: January 2026. This article was prepared with the utmost care and reflects the legal situation at the time of publication. It does not constitute legal advice for individual cases. If you have questions about the specific implementation for your property, please do not hesitate to contact us.*
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