Energy Regulation Solutions offers specialized regulatory consulting at the intersection of innovation, climate goals, and market readiness. We support developers, investors, and policymakers in navigating complex regulatory landscapes for hydrogen, CO₂, and Power-to-X technologies in the EU, Germany, and the US
✈️ The International Civil Aviation Organization (ICAO) updated the dashboard with publicly-available information on sustainable aviation fuel (SAF) offtake agreements.
📌 This dashboard covers various locations worldwide.
📌 Volumes refer to neat SAF; in case of blended SAF announcements the volumes refer to the fraction of SAF in the blend.
On 28 May 2025, the European Commission has launched the EU Startup and Scaleup Strategy, to make Europe a great place to start and grow global technology-driven companies.
✅ The EU Startup and Scaleup Strategy aims to make Europe the best place in the world to launch and grow global technology-driven companies, including deep tech companies. This is crucial for strategic technologies, such as for example cleantech and energy (including nuclear technology).
☑️ The key needs of startups and scaleups:
📌 Fostering innovation-friendly environment:
Startups and scaleups need less fragmentation, fewer administrative burdens, as well as rules that are simpler and more supportive across the Single Market.
a European 28th regime will be proposed to simplify rules and reduce the cost of failure by addressing critical aspects in areas like insolvency, labour and tax law.
The European Business Wallet will enable seamless digital interactions with public administrations across the EU through a unified digital identity for all economic operators.
The forthcoming European Innovation Act will further support innovation by promoting regulatory sandboxes.
📌 Driving better financing:
The Savings and Investments Union initiative will be key to unlocking more financing and investment opportunities in the EU.
The Strategy aims to expand and simplify the European Innovation Council, deploy a Scaleup Europe Fund to help bridge the financing gap of deep tech scale-up companies, and develop a voluntary European Innovation Investment Pact to mobilise large institutional investors to invest in EU funds, venture capital funds and unlisted scaleups.
📌 Supporting market uptake and expansion:
The Strategy introduces a Lab to Unicorn initiative, which includes the European Startup and Scaleup Hubs.
📌 Attracting and retaining top talent:
The Strategy introduces the Blue Carpet initiative, notably focusing on entrepreneurial education, tax-related aspects of employee stock options and cross-border employment.
The Blue Card Directive will be promoted to put in place a fast-track schemes for non-EU founders.
📌 Facilitating access to infrastructure, networks and service:
The Strategy proposes to simplify and harmonise diverging access and contractual conditions for startups and scaleups to technology and research infrastructures through a Charter of Access for industrial users.
On April 10, 2025, the Government of France announced the update of the National Hydrogen Strategy.
📃 The full text of the updated strategy is available via this link
✅ Key Changes and Measures:
📌 Electrolysis installation targets in the region with up to 4.5 GW targeted for 2030 and 8 GW installed in 2035;
📌 Mastery of all hydrogen equipment and technologies throughout the value chain;
📌 The deployment in France of low-carbon hydrogen transport infrastructures within hydrogen hubs;
📌 Ensuring that the necessary framework conditions are in place for the development of the French hydrogen industry, particularly in terms of access to land, procedural deadlines, the development of a comprehensive, clear and stable regulatory framework, and electrical connections;
📌 A €4 billion support mechanism for low-carbon hydrogen production to ensure that low-carbon hydrogen is competitive with fossil hydrogen over 15 years;
📌 The relaunch of the ‘IDH2 Hydrogen Technology Building Blocks’ call for projects, designed to support the development of certain critical elements of hydrogen technologies;
📌 A new call for projects for the deployment of hydrogen-powered commercial vehicles, to enable the technological development of fuel cells and tanks;
📌 Measures to support studies of synthetic fuel projects in order to bring about, by 2030, the first industrial production of synthetic fuels for aviation and maritime sectors.
On 23 May 2025, the European Commission adopted new pieces of secondary legislation and a communication relating to the Net-Zero Industry Act (NZIA).
📃 Adopted Acts:
✅ Communication providing updated information to determine the shares of the EU supply of final products and their main specific components originating in different third countries under NZIA
provides information on where the EU’s supply of net-zero technologies comes from, highlighting third country dependencies for specific technologies. This information enables the application of the ‘resilience’ non-price criterion in public procurement, renewable energy auctions, and other public interventions.
helps Member States in evaluating net-zero technology manufacturing projects eligible for strategic project status.
✅ Implementing Regulation specifying the pre-qualification and award criteria for auctions for the deployment of energy from renewable sources
These criteria include responsible business conduct, cybersecurity, and sustainability and resilience contribution.
Starting on 30 December 2025, the new rules must be applied to 30% of auction volumes (or 6 GW per year per EU country).
✅ Delegated Regulation regarding the identification of sub-categories within net-zero technologies and the list of specific components used for those technologies
replaces Annex with list of final products and specific components in NZIA.
✅ Implementing Regulation regarding the list of net-zero technology final products and their main specific components for the purposes of assessing the contribution to resilience
includes Annex with list of net-zero technology final products and their main specific components for the purposes of assessing the contribution to resilience.
✅ Implementing Decision adopting guidelines for the implementation of certain selection criteria for net-zero strategic projects
ensures a consistent selection process across Member States, through guidance on the applicable criteria for that strategic project selection.
☑️ What next?
📌 For the Delegated Regulation, following publication, the European Parliament and the Council have a 2-month scrutiny period (extendable by a further 2 months if requested), during which they can object to this act.
📌 However, there is no scrutiny period for the Implementing Regulations adopted on 23 May 2025.
On May 22, 2025, the U.S. House of Representatives passed “The One, Big, Beautiful Bill” (Bill) — legislation that proposes significant changes to energy-related tax incentives originally introduced under the Inflation Reduction Act.
➡️ Key Changes for Hydrogen:
❌ The Clean Hydrogen Production Tax Credit (IRC §45V) would be terminated for facilities that begin construction after December 31, 2025.
✅ The Clean Fuel Production Credit (§45Z) — supporting the production of low-carbon transportation fuels including hydrogen — would be extended from December 31, 2027, to December 31, 2031.
☑️ What’s Next?
The Bill now moves to the Senate, where further amendments are expected.
Final passage timing remains uncertain — but August appears more realistic than the previously anticipated July 4 timeline.
On 16 May 2025, the European Commission published its Opinion (C/2025/2004) on the statutory documents of the European Network of Network Operators for Hydrogen (ENNOH) – the independent association representing future hydrogen transmission network operators at EU level.
✅ Key Takeaways:
📌 Climate Objectives: the Articles of Association (AoA) of the ENNOH should be modified as to include climate related objectives.
📌 Membership Criteria: Only certified Hydrogen Transmission Network Operators (HTNOs) — or those undergoing certification — can be members. The “founding member” concept must align with EU law.
📌 Observer Access: Observer status should be restricted to HTNOs from countries applying EU energy law (e.g., EEA or Energy Community members).
📌 Board Composition: Rules must ensure regional balance while rewarding early movers — but with transparent limitations and future revisions.
📌 Stakeholder Engagement: Public consultations must be transparent, inclusive, and allow a default period of 2 months.
📌 Amendments & Dissolution: Changes to ENNOH’s statutory documents — including its list of members — and any dissolution must receive explicit Commission approval.
📌 Gender & Diversity: ENNOH is encouraged to integrate gender parity and diversity into board and senior role appointments.
☑️ WHAT NEXT?
The future hydrogen transmission network operators shall adopt and publish, by early July 2025, the final statutory documents, taking into account the Commission’s and ACER’s opinions.
The European Commission has started the public consultation to evaluate the operations of the Innovation Fund by 2025.
📄 Form of Feedback – the online questionnaire via this link
📅 Feedback period – 15 April 2025 – 08 July 2025
✅ What is the Innovation Fund?
📌 The Innovation Fund is one of the world’s largest funding programmes for the deployment of net-zero and innovative technologies.
📌 The Innovation Fund was established by the Emissions Trading System (ETS) Directive to support innovation in low or zero-carbon products, processes and technologies in the sectors covered by the Directive.
📌 The Fund obtains its resources from ETS allowance revenues.
evaluate the implementation of the Innovation Fund from 2020 to 2024.
will focus primarily on assessing synergies between the Fund and other EU programmes, including Horizon Europe, and the procedures for disbursing financial support.
📌 The evaluation will assess:
Effectiveness: the degree to which the Fund has succeeded in achieving its objectives of:
supporting projects that demonstrate highly innovative technologies, processes and products;
providing financial support tailored to market needs and risk profiles of eligible projects while attracting additional public and private resources;
ensuring that Innovation Fund revenues are managed to accomplish the objectives of the ETS Directive.
Efficiency: how ETS allowances have been employed to achieve the expected effects of the Fund, alongside the administrative burden associated with application, evaluation, and project implementation.
Relevance: the connection between the Fund’s objectives and the attainment of EU climate targets, particularly emissions reduction and necessary technology development, while strengthening competitiveness and resilience.
Coherence: how the various elements of the Fund function cohesively to achieve its objectives and how they synergise with the EU’s policy objectives and other programmes, such as Horizon Europe, the Recovery and Resilience Fund, and InvestEU.
EU added value: the extent to which the results and impacts of the Fund contribute to changes prompted by the Commission’s intervention over what could reasonably have been expected from national actions.