The Network of Real-World Laboratories for Sustainability generally welcomes the legislature’s initiative to improve the legal framework for testing environments, regulatory learning, and the transfer of insights to government, business, and society through a Federal Testing Act¹ (formerly the “Real-World Laboratories Act”). Such a law can make an important contribution to facilitating and initiating innovation and transformation processes, reducing associated legal uncertainties, and promoting new forms of learning between the government, academia, and the private sector. At the same time, we see a significant need for revisions to the current version of the draft bill so that the law can live up to its own claims of future-proofing, accessibility, and societal effectiveness while upholding established socio-ecological standards.

Expanding the Concept of Innovation

The concept of innovation in the draft bill is too narrowly defined. It focuses primarily on innovations that can be commercialized in a market economy, particularly technological innovations. This is not sufficient for societal transformation. Rather, a broader concept of innovation is needed—one that, with a focus on sustainability, also includes social, cultural, political, and systemic innovations.

These include, for example, community-based and public-interest-oriented economic models, new forms of local participation and the promotion of democracy, civil society self-organization to address basic needs such as healthy nutrition and care, regenerative and resilient supply and cooperation models, new forms of learning and education, and experimental approaches to public services. Such approaches are particularly crucial for the future viability of society. A federal pilot law that addresses only a fraction of this spectrum of innovation fails to realize its full potential.

We therefore suggest that the law’s objectives be explicitly aligned with economic, social, and ecological approaches to change. This would improve accessibility for a broader range of societal actors and better address the actual needs of a complex transformation.

Incorporating Transformation and Enovation

In addition to innovation, transformation must also be identified as a distinct objective. The societal change facing Germany affects not only individual technologies or markets, but also fundamental structures, paradigms, and routines. Real-world laboratories are particularly well-suited to testing such profound changes in real-world contexts because they reduce uncertainties, facilitate learning processes, and bring conflicts to light at an early stage.

It is equally important to consider “exnovation”—that is, the systematic phasing out of outdated structures, practices, models, technologies, and institutions. Sustainability transformation cannot be achieved solely by adding new elements; it necessarily also requires the orderly letting go of the old. A federal pilot program law that promotes only innovation but ignores the dynamics of exnovation and transformation remains incomplete and squanders potential for impact.

Clarifying the Concept of Real-World Laboratories

Particularly problematic is the definition of real-world laboratories used in the draft bill. It deviates significantly from the scientifically established understanding of real-world laboratories, which has been developed over many years in transdisciplinary and transformative sustainability research. In this context, real-world labs are not merely time-limited trials under real-world conditions, but rather knowledge-oriented research and development institutions in which science, practice, and society work together on socially relevant processes of change.² Scientific oversight is not an optional add-on, but a constitutive component.

The Network of Real-World Laboratories for Sustainability currently comprises over 120 active and completed real-world laboratories. Seventy-five organizations from academia and the professional sector are members of the network. All of these organizations adhere to a (significantly) different understanding of real-world laboratories than that set forth in the statutory text. A significantly different definition of real-world laboratories enshrined in law is problematic because it can lead to conceptual confusion, uncertainty, and resistance. Furthermore, this carries the risk that the established and already highly diverse real-world laboratory landscape in Germany will be reshaped or implicitly excluded. Even more serious is the fact that a narrow legal definition could shape funding programs, discourse, and practice in the long term, thereby weakening the understanding of real-world laboratories developed by the scientific community and underpinned by scientific methods—as well as the highly innovative, transdisciplinary real-world laboratory landscape that accompanies it.

In our view, there are two ways to solve this problem: Either the law’s understanding of “real-world laboratories” is explicitly expanded and made compatible with the scientific-transdisciplinary understanding (see footnote 2), or the term is defined more precisely in the law, for example as “regulatory real-world laboratories” or “innovation laboratories.” The first option is preferable to ensure broad societal acceptance and greater leverage for the law.

Anchoring Sustainability

A federal pilot project law should be explicitly guided by the goals of sustainable development. Although the draft bill makes a loose reference to the 2030 Agenda and two Sustainable Development Goals, it has not yet drawn sufficient conclusions from them for the substantive design of the law. Sustainability must not merely be mentioned as a formality in the explanatory memorandum; rather, it must be recognizable as a guiding principle within and for the law itself.

Particularly relevant here are the goals on sustainable industry, innovation, and infrastructure, as well as on sustainable cities and communities. Together with their sub-goals, these goals provide clear normative guidance for the selection, evaluation, and monitoring of pilot areas. A sustainability-focused pilot program law should therefore facilitate not only innovation, but also innovations (as well as exnovations and transformations) for sustainable development (in Germany).

We suggest systematically incorporating sustainability aspects into the text of the law and into the application review process, for example through a sustainability checklist. In this way, the evaluation of pilot projects could take into account the expected impacts on environmental, social, and economic sustainability, as well as which requirements or adjustments would be appropriate.³

Ensuring Fair Access

Another important point concerns the distribution of decision-making power. The draft primarily opens up good opportunities for those actors who possess legal expertise, administrative experience, and organizational resources. This creates the risk that larger municipalities, economically powerful actors, and well-resourced institutions will be favored, while small municipalities, startups, civil society initiatives, cultural organizations, and other niche actors will be left behind.

If the law is to be broadly effective, it requires supporting measures: low-threshold counseling, training, practical guidelines, assistance with applications, and targeted communication initiatives. These should be tailored in particular to smaller and less resource-rich actors. Otherwise, the law risks reinforcing rather than reducing existing power imbalances. The established “Reallabore” innovation portal should be utilized, further developed, expanded, and re-anchored in the law.

Involve the Scientific Community More Closely

The role of science should be significantly strengthened in the law. Real-world labs are, by their very nature, (also) hybrid scientific institutions. Scientific oversight is not only useful and important for innovation and the implementation of real-world labs, but also for evaluation, regulatory learning, and the transfer of experiences to other contexts. Science can also help systematize learning processes, assess impacts, and identify undesirable developments at an early stage.

Institutional responsibility for regulatory learning should also be broadened. It makes sense not to tie this learning solely to a single departmental framework, but to organize it across ministries. Furthermore, explicit consideration should be given not only to regulatory learning but also to regulatory unlearning—that is, the ability to phase out outdated or inappropriate regulations in a controlled manner.

Conclusion

The Federal Testing Act is an important step toward a sustainable Germany, and one that should generally be welcomed. In its current form, however, it remains too narrowly focused on technological and economic innovations and does not sufficiently address the need for a sustainability transformation. In particular, the use of the term “real-world laboratory,” the emphasis on technological innovations, the lack of integration of sustainability, and the insufficient role of science should be addressed.

A future-proof Federal Testing Act should support broad societal change, recognize and strengthen the existing real-world laboratory landscape, take sustainability seriously as a normative orientation, and ensure fair access to testing spaces. Only then can it live up to the challenge of not only supporting innovation but also effectively promoting the transformation toward a sustainable society.⁴

The Network of Real-World Laboratories for Sustainability currently comprises 75 organizations from academia and the professional sector, 120 ongoing or completed real-world laboratories, and over 400 individuals.

Authors – the network’s coordinating group:

Philip Bernert, RIFS, Research Institute for Sustainability
Markus Egermann, Leibniz Institute for Ecological Spatial Development
Pia Laborgne, Karlsruhe Institute of Technology
Daniel Lang, Karlsruhe Institute of Technology
Susanne Ober, Karlsruhe Institute of Technology
Oliver Parodi, Karlsruhe Institute of Technology
Regina Rhodius, University of Freiburg
Niko Schäpke, University of Freiburg
Roy Schwichtenberg, Ecornet – Ecological Research Network
Anja Steglich, Technical University of Berlin
Franziska Stelzer, Wuppertal Institute for Climate, Environment, and Energy
Felix Wagner, Karlsruhe Institute of Technology
Timo von Wirth, Frankfurt University of Applied Sciences

Footnotes

1 As published in the draft amendment contained in Committee Document 21(23)79

2 “A real-world laboratory refers to a transdisciplinary research and development facility that serves to conduct sustainability experiments within a geographically defined social context, to initiate transformation processes, and to sustain both scientific and societal learning processes.” (Parodi/Steglich 2021: 16; see also GAIA 2018 for a similar definition).

3 We would be happy to provide further details on this topic—and on exactly how sustainability-focused support for proposals and pilot projects might look—upon request. Please feel free to contact us at: info@reallabor-netzwerk.de

4 More detailed explanations and stronger references to the relevant passages in the draft bill can be found in the statement by Dr. Oliver Parodi (KIT) for the 27th session on May 20, 2026 (public hearing). We also refer to the network’s statement on the Real-World Labs Act of 2023.

–-> Click here for the statement