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AI & Energy

Artificial Intelligence and digitalisation for Energy

πŸ“’ New EU Initiative on AI & Energy

The European Commission has launched the public consultations regarding the initiative “Strategic Roadmap for digitalisation and AI in the energy sector”.

πŸ—“ Feedback period: 05 August 2025 – 05 November 2025

πŸ’¬ Feedback can be provided here

🎯 Goals of the Strategic Roadmap:

πŸ“Œ To exploite of synergies with the Affordable Energy Action Plan, the Energy Efficiency Roadmap, the Grids Package, the Citizens Energy Package, the Electrification Action Plan and the Heating and Cooling Strategy.

πŸ“Œ To complement the upcoming Apply AI Strategy, the Data Union Strategy, and the Cloud and AI Development Act.

πŸ“Œ To leverage the potential of digital and AI technologies for the energy system, while mitigating the associated risks and enable the decarbonisation and competitiveness of the EU economy.

β˜‘οΈ What does the initiative aim to achieve?

πŸ“Œ Accelerate deployment

  • Enable access to energy data to support innovative services
  • Help develop and test AI tools for the energy sector
  • Advance smart grids and digital twins

πŸ“Œ Boost innovation & research

  • Close the innovation gap
  • Strengthen EU technological sovereignty
  • Support clean energy R&D using AI

πŸ“Œ Integrate data centers sustainably

  • Improve planning and energy efficiency
  • Minimise grid strain and local impact

πŸ“Œ Enhance transparency & risk oversight

  • Share best practices for AI in critical infrastructure
  • Provide guidance on high-risk AI systems
  • Use AI to improve energy asset security

πŸ“Œ Create a robust governance framework

  • Foster collaboration across sectors and Member States
  • Engage with international partners and stakeholders

βœ… What next?

  • Targeted consultations and workshops
  • Discussions with Member States and expert groups
  • A high-level stakeholder event in Q3 2025

➑️ Source: Artificial intelligence and digitalisation for energy – a roadmap

Annual Energy Outlook 2025

Long-term projections: total hydrogen supplied to market, 2023-2050, hydrogen produced via steam methane reforming, 2023-2050

Figure: Long-term projections for supply and production of hydrogen

Source: Annual Energy Outlook 2025

According to the latest Annual Energy Outlook 2025 by the U.S. Energy Information Administration, even when accounting for the IRA incentives prior to the β€œOne Big Beautiful Bill Act”, hydrogen produced from natural gas remains dominated in the long-term outlook.

πŸ“Š By 2050, the majority of H2 in the U.S. is projected to be produced from natural gas via steam methane reforming (SMR). Less than 1% is expected to come from electrolyzers, despite supportive policies.

➑️ Full analysis: Natural gas remains the largest source of hydrogen in our long-term projections

Yet, this contrasts with the vision laid out in the U.S. National Clean Hydrogen Strategy and Roadmap, which foresees a more diverse production mix β€” including electrolysis, fossil-based hydrogen with CCS, and biomass/waste-derived hydrogen, playing key roles through at least 2050.

The key takeaway: Ambition and reality are still not fully aligned, when it comes to scaling up green hydrogen.

➑️ Source: U.S. National Clean Hydrogen Strategy and Roadmap

EU Hydrogen Auction

Hydrogen Bank. Innovation Fund IF25 Hydrogen Auction. Draft Terms and Conditions

πŸ“’ New EU Hydrogen Auction – Draft Terms & Conditions Open for Feedback

The European Commission has published the draft Terms & Conditions (T&Cs) for the IF25 Hydrogen Auction, the third call under the European Hydrogen Bank, set to launch by the end of 2025.

β˜‘οΈ What’s new in this round?

Proposed Budget: EUR 1.1 billion, split across three topics:

  • Topic 1: EUR 400 million – RFNBO and/or electrolytic low-carbon hydrogen
  • Topic 2: EUR 400 million – RFNBO hydrogen only
  • Topic 3: EUR 200 million – RFNBO and/or electrolytic low-carbon hydrogen for maritime applications

β˜‘οΈ Key Updates:

πŸ“Œ Broader Scope: Support extended to include electrolytic low-carbon hydrogen alongside RFNBOs

πŸ“Œ Electrolyser Resilience: Aligned with the NZIA Implementing Act (C(2025) 2900), simplifying some earlier resilience criteria

πŸ“Œ Environmental Screening: New evaluation against Do-No-Significant-Harm (DNSH) principles

πŸ“Œ No Double Funding: Projects already funded under the Innovation Fund or other EU sources are not eligible

πŸ“Œ Electricity Sourcing Plan: Projects must show a credible strategy for sourcing 100% of required electricity. For low-carbon hydrogen, at least 60% of non-renewable input must meet the 70% emissions savings threshold defined in Directive (EU) 2024/1788.

➑️ What’s next?

  • Stakeholder feedback will be gathered through the consultation
  • Feedback will be incorporated into the final design of the auction
  • The final version of T&Cs will be published with the auction launch in Q4 2025

πŸ—“ Feedback deadline: 14 September 2025

πŸ“„ Draft Terms & Conditions available here: Innovation Fund IF25 Hydrogen Auction. Draft Terms and Conditions

πŸ’¬ Provide feedback here: IF25 Auction – Draft T&Cs public consultation

Revisions to CBAM regulation

CBAM: downstream extensions, anti-circumvention and rules on electricity emissions

For general information about CBAM please visit General Introduction to CBAM.

This July, the European Commission launched a public consultation on proposed revisions to CBAM. The key aims:

  • Extend CBAM to certain downstream products – to reduce the risk of carbon leakage when production shifts outside the EU or buyers turn to non-EU suppliers.
  • Strengthen anti-circumvention measures – to close gaps and ensure the financial obligations are not avoided without valid reasons.
  • Clarify electricity-related rules – particularly the use of default values and criteria for using actual electricity emissions.

πŸ“… Feedback period – 01 July 2025 – 26 August 2025

βœ… Main Objectives of Consultation

The consultation explores:

πŸ“Œ Inclusion of selected downstream goods based on carbon leakage risk, embedded emissions, and technical feasibility.

πŸ“Œ Options to reinforce anti-circumvention tools (e.g. more reporting requirements).

πŸ“Œ Changes to CBAM rules for electricity – from emission factor updates to clearer criteria for PPAs and grid conditions.

β˜‘οΈ What next?

  • A factual summary report will be available 8 weeks after the consultation closes, followed by a full synopsis report.

➑️ Source: Carbon Border Adjustment Mechanism (CBAM) – downstream extension, anti-circumvention and rules on electricity emissions

News on the Hydrogen and Guarantees of Origin Market

hydrogen and guarantees of origin (GO) system

The latest EU report titled “Technical assistance to monitor functioning of the guarantees of origin (GO) system” provides an in-depth look at the GOs market and its impact on renewable energy and hydrogen tracking.

βœ… Key Takeaways

πŸ“Œ The GO market has achieved a healthy level of liquidity.

πŸ“Œ While transparency has improved, price discovery remains limited. GO prices vary based on factors such as technology, region, and additionality – factors not always visible to consumers. Forecasting prices remains difficult due to elements of monopolistic competition.

πŸ“Œ More than 90% of hydropower, 50% of wind, and 30% of solar electricity production in Europe is currently tracked via GOs.

πŸ“Œ The GO system is effective in tracking renewable electricity, but further harmonization is needed to reduce the risk of misuse.

πŸ“Œ Hydrogen

  • As of the end of 2023: only 0.4% of EU hydrogen production was based on water electrolysis (45 tonnes or 1.5 GWh).
  • An additional 9.2% (1,033 tonnes or 34 GWh) was produced as a green by-product (e.g., from chlor-alkali electrolysis).
  • The Hydrix index (as of January 2025) estimates green hydrogen prices in Germany at €7.80–€9.50/kg, roughly 2.5x higher than grey hydrogen (€3–€4/kg).

πŸ“Œ Hydrogen GO trading volumes

  • RFNBO certification has only been possible since December 2024.
  • Until now, certified green hydrogen has only been traded via GOs or Non-Governmental Certificates (NGCs).
  • Assuming certification, 1,500 GOs could have been issued in 2023 for hydrogen produced via electrolysis.
  • While only a few EU Member States are active in the gas GO market and even fewer support EU-wide GO trading, interest in GOs is growing:
    • Smaller projects often opt for GOs/NGCs due to lack of RFNBO compliance.
    • Larger projects (many pre-FID) are preparing for RFNBO certification to benefit from offtake obligations under the compliance market.

➑️ Source: Technical assistance to monitor functioning of the guarantees of origin (GO) system

Interaction of Certification and Standards for e-SAF Production

Last week, I had the opportunity to present my paper “Interaction of Certification and Standards for e-SAF Production” at a conference hosted by the Florence School of Regulation. This research is part of my broader PhD work on the interaction between law and technology in the regulation of Power-to-X (PtX) technologies.

βœ… Key Points of the Presentation:

πŸ“Œ General requirements

  • To be used in aviation, e-SAF must be certified under either the EU Renewable Energy Directive (RED) or the CORSIA scheme, and blended with conventional jet fuel in accordance with international standards such as ASTM D7566 and Def Stan 91-091.

πŸ“Œ Legal Framework

  • There is a lack of harmonization between the EU legal framework and international aviation fuel standards.
  • The definition of SAF in the ReFuelEU Aviation Regulation does not align with the definition used in international standards.

πŸ“Œ Certification

  • Particular attention should be given to the concept of β€œdual conformance” β€” i.e., a single batch of SAF being compliant with two different certification schemes (such as EU RED and CORSIA).
  • The coexistence of two certification schemes – EU RED and CORSIA within the EU raises questions about the feasibility of such dual conformance, a concept that is not yet defined under EU law.

β˜‘οΈ Conclusion

  • A harmonized and coherent legal framework is essential for scaling up e-SAF production and deployment in aviation.
  • Aligning EU regulations with international safety and sustainability standards will help remove existing regulatory barriers and support the widespread adoption of e-SAF across the EU.

Association of Issuing Bodies Annual Report 2024

Association of Issuing Bodies members, applicants and observers

Figure: Association of Issuing Bodies members, applicants and observers

Source: Association of Issuing Bodies, Annual Report 2024

πŸ“’ The Association of Issuing Bodies (AIB) Annual Report 2024 is out!

βœ… Key highlights from 2024:

πŸ“Œ Membership Expansion

  • By the end of 2024, the AIB had 39 members from 30 European countries, covering the EU, EEA, and Energy Community.

πŸ“Œ Electricity Guarantees of Origin

  • 30 members actively participated in the European Energy Certificate System (EECS) Electricity Scheme, issuing and transferring GOs via the AIB Hub.
  • New participants preparing for the scheme:
    • NEURC (Ukraine)
    • ERE (Albania)
    • SEDA (Bulgaria)
  • New observers:
    • ERO (Kosovo)
    • MEMO (North Macedonia)

πŸ“Œ Gas Guarantees of Origin

  • 9 members were active in the EECS Gas Scheme, including:
    • Gasgrid (Finland)
    • Enagas (Spain)
    • Brugel (Belgium)
    • E-Control (Austria)
    • GSE (Italy)
    • REN (Portugal)
    • OTE (Czech Republic)
    • Elering (Estonia)
    • Conexus (Latvia)
  • 2024 was a milestone year for the Gas Scheme Group, with six new members joining.

πŸ“Œ Hydrogen

In 2024, the following countries registered EECS hydrogen production devices:

  • Austria: 2 devices (10 MW total capacity)
  • Finland: 1 device
  • Spain: 2 devices (23.8 MW total capacity)

It’s great to see steady progress across electricity, gas, and now hydrogen, contributing to a more integrated and transparent GO market across Europe.

➑️ The AIB Annual Report is available via this link: ANNUAL REPORT 2024

Hydrogen Acceleration Act

Hydrogen Acceleration Act

Last week, the Federal Ministry for Economic Affairs and Energy (BMWK) presented the Draft Law for a new Hydrogen Acceleration Act (Wasserstoffbeschleunigungsgesetz).

πŸ“„ The Draft Law is available via this link.

βœ… Key Points:

πŸ“Œ Broader Scope Beyond Green Hydrogen

  • Unlike previous strategies focused solely on green hydrogen, the new Draft Law grants equal treatment to both green and blue hydrogen.
  • Projects producing blue H2 from natural gas with carbon capture and storage (CCS) may now benefit from acceleration measures.

πŸ“Œ Support Across the Entire Hydrogen Value Chain

The Act aims to fast-track:

  • Electrolyser deployment
  • Hydrogen imports and derivatives (e.g., ammonia, methanol)
  • PtX plants for e-fuel production
  • Hydrogen storage and transport infrastructure

πŸ“Œ Natural Hydrogen Recognition

  • Natural hydrogen will be classified as a non-mineable mineral resource under the Federal Mining Act (Bundesberggesetz).
  • This change simplifies project development by removing the need for contracts with landownersβ€”similar to how resources like coal or natural gas are handled.

πŸ“Œ Accelerated Permitting

  • No public hearing (ErΓΆrterungstermin) will take place during the approval process.
  • A planning approval decision (Planfeststellungsbeschluss) must be issued within 12 months.
  • A planning permit (Plangenehmigung) must be granted within 7 months.

πŸ“… Consultation Period:

  • The BMWK is accepting feedback from federal states and industry associations until 28 July 2025.

Nuremberg Hydrogen Conference 2025

Nuremberg Hydrogen Conference 2025

On 14 July 2025, I had the pleasure of attending the Nuremberg Hydrogen Conference, hosted by the University of Technology Nuremberg.

The event brought together leading researchers, policymakers, and industry representatives to discuss the current state and future of the hydrogen economy in Germany and beyond.

βœ… Key takeaways:

πŸ“Œ AI and clean energy:

  • The growing energy demands of AI make clean hydrogen a key enabler for a sustainable digital future.

πŸ“Œ Speed of integration:

  • While oil and gas took ~50 years and renewables ~15 years to become integral to the energy system, hydrogen should achieve this in just 5 years β€” provided the right conditions are in place.

πŸ“Œ Hydrogen production costs (2023, EU grid-mix):

  • Lowest: Finland (€4.1/kg), Sweden (€4.4/kg)
  • Highest: Cyprus (€17.4/kg), Poland (€12.4/kg)

πŸ“Œ Barriers slowing hydrogen deployment:

  • Limited willingness to pay for H2
  • Market uncertainty and lack of demand aggregation
  • Permitting delays
  • Industry is still waiting for GW-scale proof and strong public support mechanisms.

πŸ“Œ Hydrogen imports remain slow, and it is important to create competition between demand and production side.

πŸ“Œ A clear market dynamic: as hydrogen prices rise, demand drops – and vice versa.

πŸ“Œ Two-sided auctions, such as those facilitated by H2Global, are a promising tool to stimulate both supply and demand and accelerate market ramp-up.

2nd Florence Aviation Regulation Conference

2nd Florence Aviation Regulation Conference, Florence School of Regulation

Just returned from the 2nd Florence Aviation Regulation Conference, co-organized by the International Institute of Air and Space Law (IIASL), Leiden University and the Florence School of Regulation.

It was an honor to contribute to such a high-level exchange of ideas shaping the future of aviation regulation.

I had the pleasure of presenting my paper on “Interaction of Certification and Standards for e-SAF Production”, exploring how regulatory frameworks and technical standards impact the uptake of sustainable aviation fuels in Europe.

The conference addressed a wide range of topics, including:

  • Interaction between CORSIA and the EU ETS
  • Implementation of the AI Act in aviation
  • Market incentives and social sustainability in the net-zero transition
  • Regulation of non-COβ‚‚ effects in aviation