Berlin – Nearly four months after the introduction of the “12 p.m. rule,” a nationwide enforcement backlog has emerged. In April alone, authorities recorded 237,950 instances of price hikes occurring outside the permitted timeframe. The law, which took effect on April 1, 2026, was a response to the sharp rise in fuel prices caused by conflict in the Middle East. However, most federal states have been slow to act on reported violations; only Lower Saxony has issued around 1,900 fines for incidents at approximately 250 service stations. At the same time, motorists are seeing record gaps between the highest and lowest fuel prices of the day.
Violations of the “12 p.m. rule” meet with unclear jurisdictional responsibilities
The Fuel Price Adjustment Act permits gas stations to raise prices only once a day, at exactly 12 p.m.; however, price reductions remain possible at any time. Culpable violations carry the risk of fines of up to 100,000 euros. The Market Transparency Unit at the Federal Cartel Office automatically records deviations and forwards the data to the federal states.
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Lower Saxony initially charged 55 euros per warning for the April cases; one particular gas station was flagged 28 times. For violations occurring in May, the state announced standard fines, with higher penalties for repeat offenses. However, the labor-intensive process of analyzing the data is already occupying more than seven staff members there.
Tens of thousands of cases await review
In other states, the work is only just beginning. Rhineland-Palatinate was still finalizing jurisdictional arrangements in July, while Bavaria saw no reliable data to justify sanctions. Although Baden-Württemberg designated 147 responsible authorities, the datasets first required processing. Bremen had not yet received any cases by that time. Saxony also reported around 5,000 irregularities, though the process of distributing these to enforcement agencies was still underway.
The problem is particularly evident in Saxony-Anhalt, where authorities recorded around 10,000 irregularities. In April alone, these affected 151 of the state’s approximately 450 gas stations. Yet, as of mid-July, it had not been determined which agency would handle the proceedings. However, not every report constitutes proof of an intentional or negligent violation of the “12 o’clock rule.”
Price spikes hit new record highs
The Federal Cartel Office attributes many of the irregularities to possible technical causes. In the second quarter, 87.5 percent of the anomalous price hikes occurred between 11:50 a.m. and 12:10 p.m. Only 3.5 percent took place before 11:00 a.m. or after 1:00 p.m. Nevertheless, state authorities must determine which cases actually warrant a fine. At the same time, the number of daily price changes dropped to just under eight, down from instances where individual stations had previously reported up to 50 changes.
For motorists, however, the reform resulted in extreme price spikes around midday. At 12:00 p.m., prices rise by an average of around 7.3 percent nationwide. In May, the ADAC recorded a daily price spread of 14.6 cents for Super E10 and 18.4 cents for diesel. Consequently, filling a 50-liter tank cost up to 9.20 euros more at the most expensive time of day. Furthermore, ZEW and DICE calculated that margins per liter of gasoline were around six cents higher following the introduction of the “12 p.m. rule.” While the rule makes price movements more predictable, it neither reliably lowers the price level nor guarantees consistent enforcement across the board.
Author: Blackout News
Sources: Bild (22.07.26) – t-online (22.07.26) – Presseportal (18.07.26) – Bundeskartellamt (10.07.26)