I am interested in why these are false incentives. (No provocation.) A KfW 55 house is better than a building energy law house, so the subsidy achieves its goal, or am I wrong? A KfW 40 house or passive house is, of course, even better, but small steps are, in my opinion, also important. Or is KfW 55, from your point of view, not even a small step in terms of environmental protection? I do not want to question your assessment of "false incentives," but I would like to understand it.
If these subsidy programs are supposed to serve climate protection, the false incentive lies in the massive imbalance of 24,200 new build subsidies versus only 700 renovations. Our new building would have, according to the building energy law (or energy saving ordinance), a final energy consumption of about 32 kWh/sqm per year. With KfW55 it would be about 26, and with KfW40 then 19 kWh/sqm. For both the climate and the running costs, these differences are quite irrelevant, as they are absolutely very, very low in every variant. However, for a relatively small effect of only 6 or 13 kWh/sqm, there were relatively high subsidies (about 30-50K€).
If you renovate an old building from 200 kWh/sqm to 100 kWh/sqm with this subsidy amount (which is not particularly demanding), you save 100/13 = 7.7 times as much energy or CO2 compared to the subsidy from building energy law to KfW40.
In the current implementation, the construction industry—and, of course, also the builders—were actually subsidized rather than climate protection.