AI for utilities: four workflows for AI agents in the back office

AI for utilities pays off where many similar cases run through several systems under legal deadlines: grid connection requests, market communication clearing cases, customer requests and incoming documents. An AI agent reads the case, pulls context from the billing system, such as SAP IS-U or SAP S/4HANA Utilities, the grid portal, the market communication system and the CRM, and proposes how to handle it. A person releases before anything is written back to the system of record.

Grid control, SCADA and protection systems stay out of scope. The agents work in the back office of the network and retail businesses, with read access to the business systems and write access only to drafts, notes and statuses, as the energy and utilities page sets out for all four starting points. Each workflow has a named workflow owner in the business, such as the head of grid connections or of customer service, who decides when release rights widen.

In grid connections the agent checks every connection request and notification for completeness, assigns it to its statutory deadline, and prepares the query, the grid compatibility check or the reply; grid planning decides. For solar installations up to 30 kW on a property that already has a connection, that connection point counts as the most favourable one, and since 1 January 2025 the grid operator must offer a web portal and send the result of its grid compatibility check, a timetable and a cost estimate within one month (section 8(1) and (7) of the Renewable Energy Sources Act, EEG). If it does not flag within that month that the existing connection is unsuitable, the installation may be connected there.

Larger installations get eight weeks from receipt of the required information (section 8(6) EEG). Charging points for electric vehicles must be notified before commissioning, and if their combined rated power exceeds 12 kVA per installation they need the grid operator's approval, on which it must respond within two months (section 19(2) of the Low Voltage Connection Ordinance, NAV). Since 1 January 2024, controllable consumption devices have been governed by the Federal Network Agency's determinations BK6-22-300 and BK8-22/010-A, issued under section 14a of the Energy Industry Act (EnWG). Grid operators may no longer refuse or delay the connection of new heat pumps, private wallboxes, air conditioning units or batteries with more than 4.2 kW connection capacity by pointing to possible congestion; in return they may dim their draw to as little as 4.2 kW when overload threatens, and the customer pays a reduced network charge.

In practice the agent reads the application and data sheets from the grid portal and pulls the service connection and existing installations from the billing system; once grid planning has decided on connection point, cost and approval, it writes status and deadline back to both systems.

Clearing cases arise when messages between market participants are rejected or do not match the utility's own master data. The agent classifies the case, assembles the message history and master data, and proposes the correction; the market communication team decides and sends. In Germany the Federal Network Agency sets the processes, for electricity chiefly GPKE for supplier switching and master data and MaBiS for balancing group settlement, both in their current versions since 6 June 2025.

The data formats are specified by EDI@Energy at BDEW, the German energy industry association: UTILMD for master data, MSCONS for metered values and APERAK for error reports on a message. The regulator brings revised message versions into force regularly in April and October, most recently on 1 October 2026 and next on 1 April 2027, and each version can change the segments, codes and validation rules that messages fail on.

Since 6 June 2025 German supplier switches have run within 24 hours on working days (determination BK6-22-024), as Article 12 of the Electricity Directive (EU) 2019/944 requires of the technical switching process by 2026. If a supplier or grid operator is responsible for a delayed switch, the customer can claim damages from it (section 20a(4) EnWG). A clearing case that holds up a switch for two days is therefore not a backlog but a missed deadline.

The agent reads the APERAK or the rejected response, fetches the original UTILMD, the master data of the market location from SAP IS-U and resolved cases with the same error code, and proposes one of three actions: correct the master data, resend the message, or query the market partner. In the first phase it sends nothing to market partners; the team releases every correction and every message.

Utility customer service repeats a small number of case types with clear rules: instalment changes, move-ins and move-outs, meter readings and questions about switching. The agent reads the request, checks it against the contract and the consumption history in the billing system, and prepares the case so that the clerk only has to release it.

In Germany many of these rules are statutory. For household customers outside default supply, an instalment must be based on consumption in the previous billing period or that of comparable customers, and if the customer credibly shows substantially lower consumption, that must be taken into account (section 41b(3) EnWG). A customer who moves may terminate with six weeks' notice unless the supplier offers, within two weeks, to continue supply at the new address on the existing terms and can supply there (section 41b(5)).

From these rules the agent drafts the new instalment from the consumption history or the continuation offer for the new address. It compares meter readings with previous ones, routes implausible values to a person with the reason stated, and answers switching questions from the status in the market communication system.

Payment plans, goodwill and disconnection notices remain human decisions. A household customer's supply may be interrupted for non-payment, despite a reminder, only four weeks after notice, and not at all if the consequences would be disproportionate to the breach (section 41f(1) EnWG). That weighing belongs to a person, and Article 22 GDPR gives customers the right not to be subject to a decision based solely on automated processing that produces legal effects.

In the fourth workflow the agent reads incoming documents, checks them against the related case and files the clean ones; deviations go to the business unit with a stated reason. The mechanics are those of general document processing, applied to documents that exist only in the energy sector.

One example is the grid operator check in Germany's market master data register (MaStR). On the regulator's request the grid operator has one month to verify the register entries of installations on its grid, counted for renewable and CHP installations outside tenders from the commissioning report and at the latest six months after the request (section 13 MaStRV). The agent compares capacity, commissioning date and location across register entry, commissioning report and connection case, and shows the clerk only the deviations.

The agent summarises regulator notices on data formats, new determinations and BDEW application guides against the list of affected internal processes, and regulatory management assesses what each change means. Contractor invoices are checked against order, proof of work and framework agreement before they reach accounts payable.

Three constraints shape how an agent is built at a utility: information security under NIS2 and critical-infrastructure law, data protection, and employee co-determination. The NIS2 Directive (EU) 2022/2555 lists electricity undertakings that supply customers and distribution system operators among the sectors of high criticality in Annex I, and Member States had to apply their national rules from 18 October 2024.

Germany's NIS2 Implementation Act was promulgated on 5 December 2025 (Federal Law Gazette 2025 I No. 301) and entered into force the following day. Under section 28 of the new BSI Act, electricity and gas suppliers, district heating operators and operators of electricity or gas distribution networks with at least 50 employees, or more than EUR 10 million in both turnover and balance sheet total, are important entities; from 250 employees, or more than EUR 50 million turnover and EUR 43 million balance sheet total, they are essential entities, as are all operators of critical facilities. For network operators, section 5c EnWG and the regulator's IT security catalogue replace the BSI Act's risk management duties (section 28(5) BSIG), supply chain included, and the KRITIS-Dachgesetz on the physical resilience of critical facilities followed in March 2026 (Federal Law Gazette 2026 I No. 66). Which duties apply is for your information security team and compliance function to decide.

For the agent this means an architecture inside the utility's own tenant, with model access and data processing in the EU, technical users with minimal rights, logs in its own logging, and no connection to control systems or telecontrol. Customer data and consumption values are personal data, so purpose, legal basis, processor agreements and retention periods are documented before the first case runs.

In Germany, evaluating KPIs per employee engages the works council's co-determination right over technical devices designed to monitor behaviour or performance (section 87(1) no. 6 of the Works Constitution Act). At municipal enterprises and public-law institutions the Act does not apply (section 130), and the staff council under state law takes that role.

An agent for customer service, grid connection back office or documents is typically not a high-risk system under the EU AI Act. Annex III, point 2 covers AI systems intended to be used as safety components in the management and operation of critical digital infrastructure, road traffic, or in the supply of water, gas, heating or electricity. Recital 55 describes such safety components as systems used to directly protect the physical integrity of critical infrastructure or the health and safety of persons and property, such as systems for monitoring water pressure.

Amending Regulation (EU) 2026/1744 made this explicit. Under the new Article 6(1a), AI systems used solely for non-safety related aspects of user assistance, performance optimisation, service efficiency, automation or convenience or quality control do not qualify as safety components. Article 6(1b) adds that systems whose failure or malfunctioning would endanger health and safety do qualify. An agent that pre-checks connection requests or proposes instalments controls no grid assets.

A utility agent can become high-risk elsewhere. If it evaluates the creditworthiness of private customers, for example to decide on prepayment or a security deposit, Annex III, point 5(b) can apply. The classification per workflow stays with your compliance function; the AI Act check gives a first orientation, and the AI Act timeline lists which obligations apply from when, with sources.

Start with the workflow where volume, deadline pressure and written rules coincide and a workflow owner in the business has said yes; grid connections meet all three conditions, because statute sets both the deadlines and the required documents.

Before anything is built comes the baseline: cases per month and category, handling time, missed deadlines and queries per case. A Workflow Assessment measures these values in four weeks, scores the candidates on value, feasibility and risk, and ends with a fixed-price build scope for the strongest workflow.

The agent then runs in shadow mode against live cases. It drafts, the clerks decide as before, and the comparison per case type shows where release rights can widen. Disconnection notices and refusals of connection requests stay with people afterwards too.