Architect and energy consultant in one person is probably rather the exception; most have an external consultant, and normally no one would want to spend €8,000 or more on that, which is why the full subsidy of €4,000 will also be the exception.
However, the architect is relatively free in their allocation; why don’t they simply allocate a few additional hours to the energy consultant budget? With KFW40+, there should be quite a bit involved if you look at the corresponding leaflet and the scope of services described therein.
It is very likely that they themselves are not even aware that, analogous to the service phases according to HOAI, they have repeatedly acted in their capacity as a KFW expert.