There are several solutions for Tesla.
The one I think would be best is simply to change the supercharger plugs to combo2 plugs and make them CCS compatible. This would of course mean they have to supply CCS adapters to all cars but that also have the benefit that the MS can charge at other CCS stations.
Another alternative would be to put a fence around all new supercharger stations with a gate that can be opened by anyone with a Tesla. Don't know for sure but then I don't think it counts as publicly available anymore.
I do not al all like the idea of Tesla having to change the charge connectors.
I have not fully read through the proposed German requirements, however as I understand the new demand is Superchargers to have a CCS plug, and for other cars to be able to charge assuming they pay for charging.
Why should replace all Tesla charge connectors ?
Instead of modifying all Tesla cars, why not put a simple SuC to CCS adapter at every (new) SuC stall. As I understand this would be a very simple non-active one-on-one inactive adapter.
As Tela uses a pre-payment model, for a non-Tesla car to use the Supercharger, the manufacturer wll have take a license at Tesla, this is the payment.
The Tesla license will also demand the non-Tesla car to implement certain parts of the SuC protocol, as they have to do anyway for authentication to check prepayment. Without that, any CCS compatible car can connect, but of course not charge (which is fair, as they do not pay).
On first glance I would say this complies with the German requirements, as technically any CCS car CAN now connect to a SuperCharger using the simple mechanical adapter available at each stall, but it is up to the car manufacturer to enable the payment by taking a license at Tesla Motors.
No adaptation of Tesla cars and even the SuC needed, however non-Tesla cars manufacturers will have to license and adapt to Tesla's business & payment model for their customers to be able to pay for use of the SuC network.
Next to that Tesla could than also offer an optional CCS to Tesla adapter for Tesla cars to enable us to use the new CCS stalls. Everybody happy.