IKEM position paper

IKEM releases analysis of new National Water Strategy

IKEM releases analysis of new National Water Strategy

The German government adopted a new national water strategy during a cabinet meeting on 15 March 2023. The document outlines targets and measures to protect water resources and secure the water supply by the year 2050. While IKEM welcomes the ambitious scope of the new strategy, it has identified areas that need further clarification, including the specific measures that will be implemented and the mechanism that will ensure that these measures are feasible and can be financed.


On 15 March, the German Cabinet approved the National Water Strategy, which was developed by the Federal Ministry for the Environment, Nature Conservation, Nuclear Safety and Consumer Protection (BMUV).[1] The strategy outlines the challenges involved with protecting natural water resources, instituting sustainable water management practices, and securing the water supply by 2050, and describes the mechanisms required to address them. It was developed in collaboration with various stakeholders and citizens over a span of several years.

The strategy is divided into ten thematic areas describing current challenges, goals for 2050, and the measures necessary to achieve those goals. The overarching aim is to establish sustainable and climate-sensitive water management and guarantee an equitable and long-term water supply.[2] A water action programme designed to pursue this agenda outlines 78 specific measures to be implemented by 2030,[3] with most to be initiated by 2025.

An interministerial working group will be established to coordinate and monitor the implementation of the strategy. This group, which includes Länder representation, will submit an implementation report every six years as part of the review cycle established by the Water Framework Directive.[4] The report will outline the status of implementation and the necessary steps for further developing the strategy.[5]

IKEM’s assessment

The National Water Strategy represents an important step towards the development of climate-sensitive water management. To protect water resources in the long term, secure the water supply and resolve any distribution conflicts that may arise in the future as a result of climate change, it is essential to set uniform national targets with sufficiently concrete measures that can also be implemented in the short term. IKEM therefore welcomes the broad range of topics and integrative approach outlined in the strategy, which create synergies between water management and various policy and regulatory areas and incorporate actors outside the water management sector into the measures described.

Still, IKEM sees a need for improvement in some areas that fail to specify sufficiently concrete measures, provide information on the implementation or feasibility of these measures, and address the issue of financing.

Stormwater management and sponge cities

The National Water Strategy outlines crucial objectives related to high levels of soil sealing, the resulting risk of flooding in urban areas, and urban stormwater management. IKEM welcomes the fact that the development of hazard and risk maps for heavy rainfall will close the current regulatory gap regarding the lack of risk designation for precipitation-related flooding that is not directly related to surface waters.[6]

With regard to ‘sponge cities’, however, the strategy does not specify concrete measures to enforce water-sensitive development in the existing stock. Although the strategy contains numerous targets and draws a clear distinction between new and existing buildings,[7] it is not clear enough how these targets, apart from the establishment of municipal advisory structures[8], are to be implemented in the existing stock – which is precisely the area in which numerous changes will be necessary to ensure consistently water-sensitive development and protection against urban flooding and heat.

Groundwater management

With regard to groundwater management, the National Water Strategy proposes measures such as greater control of low water, the development of a real-time groundwater monitoring system, a reduction in exemptions from the permit requirement for groundwater withdrawals under Section 46 (1) WHG, and the introduction of a water register to record and disclose actual water withdrawals in a transparent way. IKEM welcomes these proposals.[9]

However, the strategy does not resolve questions regarding how the recording of actual withdrawal quantities will be enforced in practice, particularly in cases where withdrawals occur on private property. Domestic groundwater withdrawals, which are currently subject only to notification requirements under section 46 (1) WHG, are also not sufficiently monitored. It may therefore be necessary to abolish the exceptions under this section entirely, rather than relying on a ‘de minimis limit’.

Prioritisation of use

The strategy also requires improvement regarding the plan for prioritising water usage. One positive aspect is that the targets established for any necessary prioritisation decisions are clearer in this strategy than in the July 2021 draft. This will allow for the development of a nationally coordinated guideline to create a uniform framework that will serve as the basis for regional decisions on prioritisation. In addition, rules and criteria will be developed for prioritising use, for example in the event of temporary water shortages.[10][10]

The guidance framework is intended to ‘ensure […] that sufficient resources are available at all times, as close as possible to the location, for the supply of drinking water and other priority uses for the benefit of the general public’.[11] But there is no further explanation regarding other priority uses for the public good. As a result, it is unclear who can claim a priority use. For example, with regard to the water supply plans to be developed, there is explicit mention of the provision of water quantities required for the production of food and animal feed.[12] But the absolute priority afforded to drinking water supply should have been formulated more clearly.

The conflict over equitable prioritisation is also evident elsewhere. It is not limited to the distribution of water, but also influences the specifications for substance inputs. For example, the national dialogue on water already established that, as of 2030, the maximum number of large livestock units that will be permissible on farms throughout Germany is two.[13] This concrete provision was incorporated into the draft version of the National Water Strategy released on 25 November 2022,[14] but it is not included in the current strategy. Instead, the development of agricultural livestock is generally to be based on the area and ‘aligned with the objectives of climate, nature, water and emissions protection’.[15] 

Producer responsibility

There are also open questions surrounding extended producer responsibility. Consistent implementation of the polluter-pays principle under environmental law is a positive development in general: it means that manufacturers and distributors of environmentally harmful substances or products will contribute to the elimination of water pollution along the entire value chain in the future.[16]

In October 2022, the EU Commission published a draft amendment to the Urban Wastewater Directive that introduces a new extended producer responsibility.[17] This would generate financial resources that could be used to finance a ‘fourth treatment stage’ purifying wastewater from trace substances.[18] However, the Commission’s draft currently only refers to the pharmaceuticals and cosmetics sectors, while the National Water Strategy does not differentiate between sectors.

The strategy refers to the fact that regulation will be pursued at the EU level due to competitive disadvantages. It is unclear whether and to what extent other sectors in Germany will also be included. In addition, the strategy merely refers to a broad range of instruments[19] for financing by manufacturers; it would have been beneficial to also outline the possible financing models.


The water strategy lacks information on the intended means of financing of many of the measures described. The proposed nationwide development of water withdrawal charges – which so far do not apply in all federal states, mainly to the benefit of large-scale consumers – is a welcome development in this respect.[20] The seventh thematic area, which includes securing financing for the measures,[21] otherwise merely stipulates that ‘[c]urrent and emerging financing gaps […] should be identified and proposals developed for ensuring the sufficient provision of water management tasks in the future’.[22] Concrete details are only provided for the requirement of a federal programme under the Action Programme for Natural Climate Protection (ANK). In the future, the intended financing options for each measure should be outlined and more space should be dedicated to financing, which is ultimately indispensable for realising the ambitious National Water Strategy.

[1] BMUV, Nationale Wasserstrategie – Kabinettsbeschluss vom 15. März 2023 (2023).

[2] National Water Strategy, p. 15ff.

[3] National Water Strategy, p. 82 ff. The first draft of the BMUV from June 2021 contained only 57 measures; see the draft for a National Water Strategy (2021), p. 56 ff.

[4] Art. 13 (7) of Directive 2000/60/EC of the European Parliament and of the Council of 23 October 2000 establishing a framework for Community action in the field of water policy (2000), OJ L. 327, p. 1.

[5] National Water Strategy, p. 10.

[6] Cf. National Water Strategy, p. 102f., measure 51.

[7] National Water Strategy, p. 29.

[8] Cf. National Water Strategy, p. 89ff., measure 19.

[9] Cf. National Water Strategy, p. 25f and p. 83f.

[10] National Water Strategy, p. 24.

[11] National Water Strategy, p. 24.

[12] National Water Strategy, p. 24.

[13] BMU, Kernbotschaften, Ergebnisse und Dokumentation des Nationalen Wasserdialogs (2020), p. 36.

[14] BMUV, National Water Strategy Draft (2022), p. 30 und p. 90, measure 39.

[15] National Water Strategy, p. 96f., measure 39.

[16] National Water Strategy, p. 45 und p. 96, measure 37.

[17] Cf. Europäische Kommission, Vorschlag für eine Richtlinie des Europäischen Parlaments und des Rates über die Behandlung von kommunalem Abwasser (Neufassung), COM/2022/541 final.

[18] National Water Strategy, p. 95f., measure 36.

[19] National Water Strategy, p. 10; see also p. 45 and p. 9, measure 37.

[20] National Water Strategy, p. 86, measure 11.

[21] National Water Strategy, p. 59ff. and p. 105ff.

[22] National Water Strategy, p. 65.


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IKEM – Institute for Climate Protection,
Energy and Mobility e.V.