2026 GF COM Report Questionnaire on Hydrogen: Market Design, Feasibility & Supply Chain and The Future Role of Regulators

Questionnaire is structured in 4 sections:

1. Market Design - market structure evolution
2. Feasibility and Supply Chain - investment and cost recovery;
3. The Future Role of Regulators - governance and regulatory readiness.
4. Stepwise Regulatory Approach: Your Expert Opinion

Name(Required)

First Last

Country

Regulator Name

SECTION I: MARKET DESIGN - MARKET STRUCTURE EVOLUTION

1. Has a regulatory framework for the operation of the hydrogen market been established?(Required)

Yes

Other

Other(Required)

1.1. If the answer is yes to the previous question, please indicate the framework key points.(Required)

2. How does your country’s framework classify hydrogen value chain activities across different development phases?

All activities liberalized from the start

All activities always regulated

Progressive liberalization as markets mature, only natural monopoly activities (transport/distribution) remain always regulated; phase-specific regulation depending on market concentration (or other criteria)

Other approach established (please specify)

Regulation is not established yet.

Please, add any comment if you want:

Other(Required)

3. What approach is favoured by your country’s framework for hydrogen development?(Required)

Start with voluntary blending programs, gradually increase requirements

Immediate mandatory blending quotas

Market-driven blending with technical standards only

Regional pilot programs before wider implementation

No blending - focus on dedicated hydrogen networks

Not yet decided

Please, add any comment if you want:

3.1 What progression of blending levels would you consider appropriate?(Required)

1-2% initially, up to 5-10% in intermediate phase

5% initially, up to 15-20% in intermediate phase

Technology and infrastructure dependent

Based on end-user acceptance and safety assessments

Other (please specify)

Other(Required)

4. What is your country's planned approach for evolving third-party access as the hydrogen market develops?(Required)

Exemptions in initial phase, regulated access in later phases

Negotiated access throughout with regulatory oversight

Immediate regulated access for all hydrogen infrastructures

Differentiated approach by infrastructure type and ownership

Market-based access, with dispute resolution mechanisms

No difference between hydrogen and natural gas regulation

Other planned approach (please specify)

No approach planned yet

Other(Required)

Please, add any comment if you want:

SECTION II: FEASIBILITY AND SUPPLY CHAIN - INVESTMENT AND COST RECOVERY

5. What cost recovery mechanisms does your country's regulatory framework provide for hydrogen infrastructure at different stages of market maturity?(Required)

Full cost recovery through specific tariffs from the start

Gradual transition from public funding to market-based recovery

Risk-sharing mechanisms between investors and consumers

Phase-specific approaches (like natural gas regulation) with regular reviews for infrastructure

Other, please specify

Not yet decided

Other(Required)

Please, add any comment if you want:

6. Is public funding support set to different phases of hydrogen market development?(Required)

Heavy public funding support in initial phase, market mechanisms in mature phase

Consistent public funding support not only in initial phase but also throughout development

Minimal public support - rely on market forces

Technology-specific support regardless of phase

Consumer protection focus - limit impact on energy bills (no matter of other profiles)

Other, please specify

Not yet decided

Other(Required)

Please, add any comment if you want:

7. Which types (“colours”) of hydrogen are prioritised or promoted within regulatory and support frameworks in your country?(Required)

Green hydrogen (renewable-based)

Blue hydrogen (Natural gas with CCS)

Other low-carbon hydrogen

No specific colour should be promoted (technology-neutral approach)

Not yet determined

Please, add any comment if you want:

8. Do you see a risk of stranded costs for hydrogen infrastructures due to uncertainty in the demand boost?(Required)

No, because energy transition will require hydrogen development

No, but regional and international standards are relevant for speed of development

Yes, there is such a risk and regulators should take into consideration and be very prudent

It will depend upon public funding support

Please, add any comment if you want:

9. Has the hydrogen infrastructure tariff methodology been designed or at least decided in its major principles in your country?(Required)

Yes, it has been already designed

At least it has been decided that hydrogen infrastructure will need separate tariff methodology

At least it has been decided that existing gas tariff model can be adapted

Other kind of decision

Not yet determined

Other(Required)

Please, add any comment if you want:

SECTION III: THE FUTURE ROLE OF REGULATORS - GOVERNANCE AND REGULATORY READINESS

10. How does your country's regulatory framework for hydrogen provide for managing the gradual development of the hydrogen market, and which authorities are involved?(Required)

Regular formal reviews with stakeholder input

Continuous monitoring with adaptive regulatory responses

Predetermined regulatory roadmaps with limited flexibility

Hybrid approach combining scheduled reviews and responsive adjustments

Market-driven evolution with minimal regulatory intervention

Not yet decided

Please, add any comment if you want:

11. How does your country's regulatory framework for hydrogen cope with consumer protection issues?(Required)

Enhanced protection to avoid impact of hydrogen costs on consumers (esp.ly households)

Phased measures based on market maturity

Minimal protection in early phases to encourage development

Other measures for customer protection

Not yet determined

Other(Required)

Please, add any comment if you want:

12. Is the Regulator role set in the development of the hydrogen market?(Required)

Yes

Not yet decided

12.1 Which is the regulator role in your country’s framework?(Required)

Granting licenses and permits for projects

Establishing market rules and trading mechanisms

Regulating hydrogen transmission and distribution network tariffs

The same as in natural gas regulation

Other roles different from above (please specify)

Other(Required)

Please, add any comment if you want:

13. Does your country’s framework for hydrogen have some mechanisms to capture lessons learned from early phases?(Required)

Sandbox or pilot projects

Regular stakeholder consultations and feedback loops

Cross-jurisdictional knowledge sharing platforms

Academic partnerships for independent assessment

Other mechanism established in the framework (please specify)

No learning mechanism envisaged by the framework

Other(Required)

Please, add any comment if you want:

13.1. Which features have established regulatory sandboxes specifically for hydrogen projects in your country’s regulatory framework?(Required)

Broad exemptions for pilot projects

Limited exemptions to specific activities or technologies

Derogations are compensated by strict consumer protection safeguards

These aspects are still under consideration/evaluation

Please, add any comment if you want:

13.2. What exemptions have been set in the hydrogen sector sandboxes?(Required)

Innovation/demonstration value of the project

Limited scale and duration

No adverse impact on existing customers

Clear learning objectives and knowledge sharing

Unbundling exemptions

Please, add any comment if you want:

13.3 What maximum duration is set for sandbox hydrogen projects?(Required)

2-3 years

4-6 years

7-10 years

Project-specific duration (upon proponent’s proposal)

13.4 What temporary exemptions are set from unbundling requirements?(Required)

Complete exemption for integrated hydrogen projects

Accounting separation only in initial phases

Exemption limited to new-build infrastructure

No exemptions - apply full unbundling from start

Different approaches for different hydrogen technologies

Other (please specify)

Other(Required)

Please, add any comment if you want:

SECTION IV: STEPWISE REGULATORY APPROACH: YOUR EXPERT OPINION

A recent report from RETA suggests an adaptive and gradual approach to hydrogen regulation. Even if your country has not yet determined any regulatory approach to hydrogen, we suggest that you have a look at this report (available on the GF sectoral update on the ERRA website) and try to answer the following questions as an expert. All questions within this section IV are not mandatory; you can leave them blank if you don’t feel sure enough. However, we strongly suggest that you consult with other expert colleagues of yours and provide a considerate answer.

14. Do you deem it useful to approach hydrogen regulation with a stepwise approach according to the different phases of the hydrogen market and infrastructure development?

Yes

14.1 Which kind of criteria would you consider more appropriate to distinguish between: a) Initial phase (pilots/demonstrations), b) Intermediate phase (commercial scale-up but limited number of hydrogen operators yet), c) Mature phase (full market operation)

Technology-driven phases, based for instance on cost-competitiveness thresholds of green Hydrogen

Production volume-based phases (e.g., 10GW installed capacity of green Hydrogen)

Customer-based phases (industrial only, industrial+transport, full market)

No formal phase distinction yet, only qualitative concept and postpone any decision

Please, add any comment if you want:

15. What regulatory approach would you favour for the initial development phase of hydrogen markets?

Regulatory sandbox with time-limited exemptions

Light-touch regulation with enhanced monitoring

Extension of existing gas regulatory framework

Completely new hydrogen-specific framework from the start

Market-led development with minimal intervention

Please, add any comment if you want:

15.1 What specific exemptions or light-touch measures do you consider most important?

Unbundling requirements

Third-party access obligations

Price regulation

Licensing/authorisation procedures

Please, add any comment if you want:

16. How would you approach the transition from initial to intermediate phase regulation?

Pre-defined triggers based on market metrics (volume, number of players, customers served)

Periodic reviews with discretionary decisions

Automatic sunset clauses for exemptions

Hybrid approach combining triggers and reviews

Case-by-case assessment

Please, add any comment if you want:

16.1 What specific metrics would better placed to trigger the transition?

Market concentration ratios

Total production capacity thresholds

Number of end-users served

Infrastructure investment levels

17. What timeline do you foresee for transitioning between regulatory phases?

Initial phase: 2024-2027, Intermediate: 2027-2032, Mature: post-2032

Initial phase: 2024-2030, Intermediate: 2030-2035, Mature: post-2035

Even slower

Other (please specify)

Other

18. Which regulatory principles should apply differently across development phases?

INITIAL PHASE

INTERMEDIATE PHASE

MATURE PHASE

19. How do you assess the overall readiness of your regulatory framework for implementing an adaptive and gradual approach to hydrogen regulation as suggested by RETA?

Well-prepared with clear phase-transition criteria

Basic framework in place, details need development

Early stages - significant framework development needed

Waiting for policy direction before developing detailed frameworks

Adopting approaches from other jurisdictions

I don't know

Please, add any comment if you want: