Austria did it in 2021.
Germany starts in 2026.
Spain is still cleaning up the mess.

In 2019, the EU passed the Clean Energy for All Europeans package. Buried inside it was something genuinely radical: a legal requirement for every member state to allow citizens to form energy communities — groups of people who collectively produce, consume, store and trade renewable electricity, bypassing the traditional utility model.

Every EU country got the same directive. They had until 2021 to implement it. What happened next is a masterclass in how political will — or the lack of it — determines whether a law on paper becomes a reality on a rooftop.

Austria moved immediately and aggressively. Germany debated, amended and deferred for four years. Spain introduced a tax on solar and spent a decade in regulatory paralysis before slowly reversing course. Switzerland — not an EU member but watching closely — finally enacted its own version in January 2026.

Here's the full comparison, with data.

🇦🇹 Austria: the blueprint

The most useful number for understanding Austria is not a solar statistic. It's this: 6,000+ energy communities operational by mid-2025 — four years after the law passed. That is what full implementation looks like.

Austria's EAG created two distinct community models. The Renewable Energy Community (EEG) operates within a single grid operator's concession area — roughly equivalent to Switzerland's LEG. The Citizen Energy Community (BEG) is geographically unlimited across Austria. In both cases, the law was clear, the grid operators were required to facilitate sharing, and the regulatory authority enforced it. The result: record solar installations in 2024, 95% renewable electricity share, and an energy sector that looks fundamentally different from four years ago.

One detail that matters for Switzerland: Austria's two-tier model (local and national) was specifically designed to serve different use cases. Local communities work for apartment buildings and neighbourhoods. The national BEG model enabled larger cooperatives spanning cities. Switzerland's LEG currently mirrors the local model. As adoption grows, the question of extending geographic scope will become relevant — Austria's experience shows it's worth building in from the start.

🇩🇪 Germany: technically first-class, politically last

Germany has more installed solar capacity than any other European country — 90 GW by end 2024, 1,192 W per person. It invented the modern feed-in tariff. It had energy cooperatives (Genossenschaften) before anyone else was talking about community energy. And yet it took until November 2025 to pass the law enabling energy sharing.

The explanation is structural. Germany's energy law (the Energiewirtschaftsgesetz, EnWG) is extraordinarily complex, written to serve a centralised utility model, and amended so frequently that the industry has largely given up expecting regulatory stability. Every change of government brings a new energy ministry priority. The current sharing framework (§42c EnWG, in force from June 2026) was watered down from earlier drafts, restricted to single distribution network areas, and still doesn't resolve the Mieterstrom legal uncertainty created by the May 2025 BGH ruling.

The irony is that Germany has the infrastructure, the solar capacity and the technical expertise to be leading this transition. What it lacks is a stable, clear regulatory framework that doesn't get reopened every election cycle. For Switzerland watching from across the border, this is the cautionary tale: good intentions and strong solar numbers don't automatically translate into community access.

🇪🇸 Spain: big solar, broken rules — and finally changing

Spain is the most complicated story of the three — and the most instructive. It has the best solar irradiance in Western Europe. It has been installing utility-scale solar faster than almost anywhere else. At 88 GW of total renewable capacity, it is the second-largest renewable market on the continent. And yet its citizens have had almost no access to the energy their country produces.

The reason: a decade of actively bad regulation, followed by years of structural inertia that good intentions have only slowly begun to reverse.

After repeal, Spain enabled collective self-consumption — but with a 500-metre geographic limit that made cross-building sharing nearly impossible in practice. The limit was gradually extended: to 1km in 2022 (rooftop installations only), then to 2km in 2023 for all technologies. In June 2025, the government passed RDL 7/2025 to extend this to 5km — but the Royal Decree-Law was subsequently rejected by Congress before it could take effect. As of March 2026, the legal distance limit is still 2km. A new draft Royal Decree proposing 5km (with stricter conditions on installation type) entered public consultation in October 2025 and is expected to pass in 2026 — but is not yet law. Community energy exists in practice primarily in Basque Country and Navarra, where regional governments moved ahead of national policy, and covers only around 4% of municipalities.

The structural disconnect is striking: Spain generates enormous amounts of solar electricity, most of which flows to large utilities and wholesale markets. Citizens sit below the high-voltage lines paying retail prices for power generated 50 kilometres away on utility farms. The community energy framework that could change this is finally being built — but Spain is building it 7 years late, on a foundation damaged by the sun tax and subsequent regulatory volatility.

🇨🇭 Switzerland: starting in 2026, with the playbook already written

Switzerland is not an EU member. It was under no obligation to implement the 2019 directive. It chose to anyway — in its own form, under its own timeline — because the economics and the logic are undeniable regardless of which bloc you belong to.

The LEG (Lokale Elektrizitätsgemeinschaft) that came into force in January 2026 is structurally closest to Austria's EEG model: community sharing within a single distribution network area, with producers selling locally at rates significantly above feed-in tariffs and consumers buying at rates below standard grid prices. The gap that utilities have been keeping for decades starts to close.

The advantage Switzerland has that Austria didn't in 2021 is that the playbook is written. Austria ran the four-year experiment. The operational models work. The billing systems exist. The investor calculus for rooftop solar changed permanently once local selling prices were established. Switzerland doesn't need to figure out what works — it needs to execute quickly enough that the communities forming now have the largest supply base by the time demand fully arrives.

The map: where solar capacity is vs. where community access exists

What this means if you're in Switzerland right now

The comparison across these four countries points to one clear conclusion: the countries that moved earliest and most decisively saw the fastest acceleration in both community adoption and solar installation. The mechanism is the economics. Once producers can sell locally at 15–25 Rp./kWh instead of 6.8 Rp./kWh, the investment case for rooftop solar changes. More installations create more supply. More supply creates larger communities. Larger communities cover more of each member's consumption. The savings grow.

Austria ran this experiment from 2021. Switzerland starts it in 2026. The countries that didn't move — or moved too slowly or with too many restrictions — have solar capacity that generates electricity flowing to wholesale markets while their citizens pay retail prices.

The difference between the Austrian outcome and the Spanish outcome wasn't solar irradiance. It wasn't natural resources. It was whether the regulatory framework made community sharing the path of least resistance, or the path of most resistance.

Switzerland's LEG makes it the path of least resistance. That's the starting condition. What happens next depends on how quickly communities form, how large they grow, and how many producers and consumers register before the early-mover advantage narrows.

1. Register now — communities forming today will have the largest supply base by 2027–2028, when the LEG flywheel is fully spinning.

2. Get matched — Upgrid connects you to the nearest active community in your grid area.

3. Lock in your rate — community members who register early receive the guaranteed lower rate in their contract from day one of supply.

4. Benefit from compounding — as more producers join, community coverage increases. Your savings grow without any further action.