Insect protection and floodlighting: what § 41a BNatSchG means for sports facilities

§ 41a was added to the Federal Nature Conservation Act (Bundesnaturschutzgesetz) by the Insect Protection Act of 18 August 2021. Under Article 4(3) of that Act, it only enters into force on the day the ordinance under § 54(4d) enters into force. The official version of the Act, last amended on 30 September 2026, still lists § 41a as “future entry into force”.

The ordinance is meant to set limit values for light emissions, technical requirements and the notification obligation. According to the explanatory memorandum to the Act, the avoidance requirement can only be enforced after that. The Leibniz Institute of Freshwater Ecology and Inland Fisheries names 2027 as the federal government’s target date under the National Biodiversity Strategy.

The provision covers “lighting on roads and paths, external lighting of structures and land, and illuminated or light-emitting advertising installations”. Once it applies, these points matter:

• New lighting must be built and operated so that wild animals and plants are protected from the light pollution defined in the ordinance
• This also applies to substantial changes
• The Act names an obligation to retrofit or upgrade existing installations only for public roads and paths
• If a project needs approval, the competent authority issues the necessary orders at the same time
• Without approval, it must in certain circumstances be notified to the nature conservation authority beforehand
• State law on protection against light pollution remains unaffected

The word sports facility does not appear in the Act. The research report preparing the ordinance (BfN-Schriften 772, 2026) classes sports venues with the lighting of land and facilities and treats them separately there. It also notes that lighting is usually already part of a structure simply by being fixed to a mast.

Substantial change is also discussed there: if the luminaire body is replaced during a retrofit to new technology, the authors regard this as a substantial change. The explanatory memorandum to the Act gives conversion to LED as an example, although in relation to the retrofit and upgrade obligation for street lighting.

The report is a research proposal, not law. Only the ordinance will settle the question with binding effect, and in individual cases the competent authority.

The authors want to avoid conflicts with the technical standards. The minimum requirements of technical standards such as DIN EN 12193 are therefore to be used as a basis. Their regulatory options for sports venues:

• Limit the lighting class in time to actual use
• Dim or switch off no later than one hour after use
• As a further option, limit the average illuminance to 110 % of the minimum requirement
• No aiming of luminaires at angles above 30°
• Limit upward light (ULR) to 5, 2 or 0 % at most depending on the area, and to 0 % in nature reserves and comparable areas
• Colour temperature of no more than 4000 K in industrial, central and commercial areas, otherwise no more than 3000 K

These values are proposals. Whether and how they will be included in the ordinance is not yet certain. Views from practice quoted in the report point out that requirements that are too strict could hinder the conversion of existing sports facilities to more efficient technology.

The research report names Baden-Württemberg, Bavaria and Hesse as states with their own provisions in state nature conservation law. We are not aware of an explicit rule for sports floodlighting there:

• Baden-Württemberg, § 21 NatSchG: interference with insect fauna through artificial lighting in the outdoor area is to be avoided, and new outdoor lighting must be assessed for its effects
• Bavaria, Art. 11a BayNatSchG: the same duty to avoid, plus a check when lighting systems are installed in the outdoor area and restrictions near protected areas
• Hesse, § 35 HeNatG: avoidable lighting should not be installed, and municipalities can adopt a lighting by-law

In 2020, during the legislative process, the Landessportverband Baden-Württemberg (state sports federation) criticised that sports lighting was not taken into account in the draft. Bavaria’s guide for municipalities names sports facilities as an example for limiting light pollution in the surroundings. The permit law for floodlighting at sports venues also differs from one federal state to another. Ask the local building authority and the nature conservation authority early.

Some requirements can already be identified, independently of the ordinance. The technical annex to the Kommunalrichtlinie sets a colour temperature of generally no more than 3000 K and ULR 0 % for funded sports facilities. The other sources point in the same direction:

• Colour temperature: no more than 3000 K; according to the research report, the blue-light share rises markedly above this for almost all light sources
• Light emission: direct light from above downwards and only onto the pitch, no upward light
• Quantity: no brighter than necessary, dimmed for training, separate switching of individual areas
• Time: switch off or dim after use, use time programmes
• Surroundings: clarify early whether protected areas and protected biotopes are nearby

Colour temperature is only one building block. The industry association ZVEI considers a limit of 3000 K alone to be of little help and stresses light distribution, brightness and control. All our floodlights are available in 3000 K, and we determine light distribution and operating times for your site during planning.