CO2 Cost Allocation: Tenant Guide for Germany

Utilities & Service Charge Billing 3 min read · published September 07, 2025

Many tenants in Germany receive utility bills that include allocated CO2 costs. Errors in the breakdown, incorrect allocation keys or missing receipts often lead to excessive charges. This text explains in plain language the common mistakes in CO2 cost allocation, how you as a tenant can check documents, meet deadlines and file an objection in time if the calculations are incorrect. I provide concrete checkpoints, practical wording examples for an objection and legal foundations from the BGB as well as the regulations on heating and operating cost accounting in Germany. The goal is that you can assess your rights confidently and, if necessary, prepare the next steps — up to proceedings before the local court.

What are common errors in CO2 cost allocation?

Recurring problems in CO2 cost statements include incorrect billing periods, inappropriate allocation keys, missing receipts, rounding mistakes and unclear cost attributions. Check systematically: billing period, distribution keys used, previous year values and the assignment of CO2 costs to billable items.

Respond to legal notices within deadlines to avoid losing rights.

Concrete checkpoints

  • Check whether the statement includes receipts for CO2 costs and whether meter/readings are traceable.
  • Are the technical bases (e.g. billing by consumption or living area) consistent with the tenancy agreement?
  • Are amounts correctly allocated to the apartment and are there obvious calculation errors?
  • Are there missing details about the origin of CO2 costs or transparent invoices from energy suppliers?
  • Have legal deadlines and billing periods been observed?

Under German tenancy law, the landlord must present utility costs clearly and transparently; relevant rules are found in the Civil Code and specific ordinances.[1][3]

How and when tenants should react

If you discover errors, first document all evidence and then file a written objection within the objection period. Specify the exact items you dispute (e.g. missing receipts, incorrect allocation). Request inspection of accounting documents and propose a correction deadline. If the landlord does not respond, you may withhold the disputed amount initially and eventually consider court action.

Keep copies of all letters, statements and photos in a safe place.

Frequently Asked Questions

What is the deadline to object to the utility bill?
The statutory deadline is generally twelve months after receipt of the bill; however, check your bill immediately so you do not miss deadlines.
Can the landlord demand CO2 costs without proof?
No, the landlord must substantiate the costs and disclose the basis of allocation; if receipts are missing, you can object and possibly refuse payment.
What if the dispute goes to court?
Disputes over utility costs are normally heard at the local court; pay attention to the rules of civil procedure and evidentiary requirements.[1]

How-To

  1. Check documents: gather the statement, contracts and receipts and make photos or scans.
  2. Observe deadlines: note the receipt date of the statement and the statutory objection period.
  3. Draft an objection: write a brief, factual letter specifying the contested items and request inspection.
  4. Court resolution: if no agreement, consider filing a claim at the local court; prepare your evidence and documentation.

Key Takeaways

  • Check each CO2 item and immediately request missing receipts.
  • Object in writing and on time to protect your rights.

Help and Support / Resources


  1. [1] Bürgerliches Gesetzbuch (BGB) §§535–580a — Gesetze im Internet
  2. [2] Heizkostenverordnung (HeizKV) — Gesetze im Internet
  3. [3] Betriebskostenverordnung (BetrKV) — Gesetze im Internet
Bob Jones
Bob Jones

Editor & Researcher, Tenant Rights Germany

Bob writes and reviews tenant law content for various regions. They’re passionate about housing justice and simplifying legal protections for tenants everywhere.