BWO comments on the draft bill for the KRITIS umbrella law
As the industry association for offshore wind energy, we submitted our statement on the draft of the KRITIS umbrella law on September 4, 2025, within the deadline. The aim of the law is to strengthen the resilience of critical infrastructure and to take into account the changed safety requirements.
Our key points:
- Responsibility and coordination: The Federal Network Agency (BNetzA) is to become the central authority for the energy sector. However, close coordination between the BNetzA, BSH, BSI, BBK and the Maritime Security Centre (MSZ) is necessary for the maritime sector to avoid duplication of structures and ensure clear reporting chains.
- Transparency and predictability: The BNetzA's security catalog must remain practical and stable – no "moving targets". Changes must be announced early and coordinated with the industry. Subsequent regulations issued by the BMI must also not lead to investment risks.
- Risk-based approach and international standards: Resilience plans must build on existing standards such as ISO/IEC 27001 and ENISA guidelines and consider cross-border infrastructure projects from the outset. Existing certifications should be recognized as proof to avoid duplicate audits.
- State monopoly of the use of force: Civilian operators must not be forced into state security tasks. The installation of radar or sensor systems for military situational awareness exceeds the scope of civilian responsibility and must be state-funded.
- Compliance costs and financing: The draft legislation fails to provide specific cost estimates. The financial burden of additional security requirements must remain proportionate. Financing through the defense budget or European programs should be explored.
The BWO supports the objective of the law, but calls for legally clear, coherent and practical procedures as well as the close involvement of the offshore wind industry in its further development.