ACER’s European hydrogen markets 2025 Monitoring Report

The ACER’s European hydrogen markets provides 2025 Monitoring Report a realistic snapshot of the current state of development of the European hydrogen market.

✅ Key Takeaways:

📌 As of October 2025, only two Member States, Denmark and Ireland, have notified the Commission of the completion of RED III transposition.

📌 Despite a strong 51% annual increase in installed electrolyser capacity in the EU in 2024, the installed capacity of 308 MW (2024) and the 1.8 GW capacity under construction still fall well short of a realistic trajectory toward the 2030 EU (40 GW) and Member States (48-54 GW) targets.

📌 At around 8 EUR/kgH2, the average cost of RFNBO hydrogen in the EU currently remains four times higher than that of conventional hydrogen from natural gas (just over 2 EUR/kg).

📌 Electricity supply costs, excluding grid tariffs, may account for up to 50% of the levelised cost of renewable hydrogen, depending on the electricity supply mix, with substantial regional variations across the EU.

📌 Uncertain future demand for renewable hydrogen, driven by the current cost, makes it difficult for hydrogen network operators (HNOs) to align network development with demand evolution, increasing the financial risks associated with this uncertainty. Adaptive network planning, reflecting the latest market trends, is essential to ensure efficient investment and cost control.

📌 Low-carbon hydrogen produced from natural gas with carbon capture and storage (CCS) could support market development and accelerate decarbonisation in some sectors. With current production cost estimates at just below 3 EUR/kg, low-carbon hydrogen with CCS is more competitive than renewable hydrogen.

📌 Funding availability is increasing, but implementation remains slow. The European Commission has allocated more than €20 billion through various hydrogen-related programmes, including auctions under the European Hydrogen Bank. In addition, the EU Hydrogen Mechanism has been launched to facilitate supply–demand matching and accelerate hydrogen market creation.

➡️ Source: The European Union Agency for the Cooperation of Energy Regulators. European hydrogen markets 2025 Monitoring Report

Green Hydrogen & RFNBO Criteria

Institute of Energy Economics at the University of Cologne gGmbH (EWI). Green hydrogen production under RFNBO criteria ‐ Analyzing the system and business case perspective.

Today I took a closer look at a new EWI study: “Green hydrogen production under RFNBO criteria – Analyzing the system and business case perspective” (2025).

✅ Key Takeaways:

This analysis examines the impact of the RFNBO criteria on green hydrogen production from system and business perspectives, with particular attention to how the criteria affect costs, capacity expansion, and the need for system flexibility.

📌 From a system perspective:

  • Implementing all RFNBO criteria increases electrolysis capacity by over 3% across Europe to meet predefined demand, while average full-load hours decline by around 200 hours.
  • Applying all RFNBO criteria with hourly matching increases average hydrogen supply costs by around 10 EUR/MWh (+8%) across Europe, driven primarily by additionality requirements and the shift from daily to hourly matching.
  • In Germany, expected to be the largest hydrogen offtaker in Europe, the impact on marginal hydrogen costs is higher than the EU average (+16%).
  • These effects highlight distributional impacts between sectors: while marginal electricity costs decline due to surplus renewables entering the market, additional system costs remain within the hydrogen sector. This implies a cost shift from electricity consumers to hydrogen producers.
  • Average EU electricity costs fall by around 5%, and marginal CO₂ certificate costs by around 2%.
  • Applying all RFNBO criteria adds over 25 GWel of additional RES capacity across Europe. In Germany, total installed RES capacity increases by 17%.
  • Adding RFNBO criteria reallocates capacities from the electricity market to hydrogen production.
  • With stricter temporal correlation requirements, hydrogen production increasingly relies on RES with high full-load hours (onshore and offshore wind), leaving more volatile solar generation to the electricity market.

📌 From a business perspective:

  • Tighter matching requirements push portfolios toward dedicated renewables and short-term flexibility.
  • Under Hourly Matching and a baseload supply profile, PV is often combined with large batteries; adding hydrogen storage can shift flexibility from the electricity sector to the hydrogen sector.
  • Results show that LCOH are more sensitive to constraints from the business perspective: in the baseline, they rise from around 150 EUR/MWh (No Criteria) to almost 180 EUR/MWh (Hourly Matching), an increase of +19%, with the largest jump occurring between Daily and Hourly Matching.
  • Sensitivity analyses reveal a much stronger impact than in the system perspective, especially under Hourly Matching, where LCOH range from about 170 EUR/MWh up to 370 EUR/MWh.
  • The difference between Monthly and Hourly Matching spans from roughly 15 EUR/MWh to over 90 EUR/MWh.

➡️ Source: EWI (2025). Green hydrogen production under RFNBO criteria ‐ Analyzing the system and business case perspective.

Hydrogen Mechanism

🔹 New milestone for the EU hydrogen market! 🔹

On 12 November, the European Commission launched the first call for interest under the Hydrogen Mechanism, which is a key step to connect potential suppliers and buyers of renewable and low-carbon hydrogen and its derivatives across the EU.

🔗 Official announcement

🔗 Hydrogen Mechanism platform

💡 What is the Hydrogen Mechanism?

An online platform that supports market development for renewable and low-carbon hydrogen and its derivatives, such as ammonia, methanol, and electro-sustainable aviation fuel (eSAF).

📅 Key timeline:

  • 12 Nov 2025 – 2 Jan 2026: Submission phase: Suppliers are invited to submit supply offers.
  • 19 Jan 2026: Publication of anonymised supply offers.
  • 19 Jan – 20 Mar 2026: Off-takers express their interest.
  • 31 Mar 2026: Results available to participants.

➡️ Why it matters:

  • Connects future demand and supply, reducing market uncertainty;
  • Increases transparency and visibility of potential partners;
  • Facilitates hydrogen infrastructure and financing access;
  • Encourages market engagement and new business opportunities.

The Hydrogen Mechanism is another important step toward building a hydrogen market.

Federal Court of Auditors report

Federal Court of Auditors Report, Germany, Hydrogen Strategy

📢 Germany Must Revise Its Hydrogen Strategy under the Federal Court of Auditors (Bundesrechnungshof) Report

✅ Main Findings:

📌 The German government considers hydrogen a key pillar of the energy transition, aiming for Germany to become climate-neutral by 2045.

📌 The federal government has already allocated more than €7 billion in funding, mainly as subsidies, for 2024 and 2025. Despite this significant financial commitment, the objectives of the national hydrogen strategy have not yet been achieved.

📌 The Federal Court of Auditors found that both supply and demand for green hydrogen in Germany have not developed as planned. A sufficient hydrogen supply is intended to come from domestic production and at least half from imports. However, the German government will not meet its domestic production targets for green hydrogen by 2030, nor will anticipated import volumes cover the expected demand.

📌 Green hydrogen remains significantly more expensive than fossil fuels such as natural gas. Since competitive production or import prices are not foreseeable in the near future, long-term government subsidies are likely to remain necessary. To bridge the price gap between hydrogen and natural gas, import costs alone could place a burden of €3 to €25 billion on the federal budget by 2030.

☑️ Reality Check

The Federal Court of Auditors recommends that the Federal Government:

  • review the hydrogen strategy and its current implementation, reassessing whether and when green hydrogen can be made available in sufficient quantities, at competitive prices;
  • evaluate, as part of this review, the actual contribution the hydrogen economy can make to the energy transition as a whole;
  • revise the hydrogen strategy to ensure that supply, demand, and infrastructure are developed as synchronously and cost-effectively as possible; and
  • develop a “Plan B”, if necessary, to achieve climate neutrality by 2045, even without a permanently subsidised hydrogen economy.

➡️ Source: Bundesrechnungshof: Umsetzung der Wasserstoffstrategie stockt: Erhebliche Risiken für Energiewende, Industriestandort und Bundesfinanzen

ReFuelEU Aviation Annual Technical Report

The European Union Aviation Safety Agency (EASA) has published the first ReFuelEU Aviation Annual Technical Report 2025

✈️ The European Union Aviation Safety Agency (EASA) has published the first ReFuelEU Aviation Annual Technical Report.

☑️ Synthetic Aviation Fuels (e-SAF) Market Development as of June 2025:

  • The global pipeline for e-SAF facilities comprises 94 announced demonstration or commercial projects, with a combined capacity of 7.2 million tonnes per year.
  • The European Economic Area (EEA) is the frontrunner, accounting for 59% of projects and 42% of planned capacity.
  • Due to the absence of binding e-SAF mandates outside the EU and UK, many projects are oriented toward exporting to the European market.
  • Planned non-EEA capacity faces both slow project progress and the challenge of meeting the EU’s stringent sustainability criteria before these fuels can be imported into the EU.

✅ Key Takeaways:

📌 EU SAF production capacities are projected to be sufficient to meet the minimum SAF shares defined under the ReFuelEU Aviation Regulation for 2030 (excluding e-SAF).

📌 A continuous scale-up of production will be necessary to establish a well-functioning market and achieve the 2035 ReFuelEU targets, which rise to 20% that year. The scale-up of e-SAF production in the EU is still lagging.

📌 As of today, none of the se-SAF facilities in the EU have reached Final Investment Decision (FID), putting at risk the 2030 sub-target for e-SAF. To meet that target, given development lead times, several facilities must reach FID by 2026 at the latest.

📌 Of the feedstock used for SAF supplied in the EU, 69% originated from non-EU countries, with China contributing 38%, Malaysia 12%, and Finland 10% as the largest European contributor.

📌 In 2024, 25 aviation fuel suppliers (out of 83) reported a total supply of 193 kt of SAF. Fewer than ten suppliers accounted for 80% of this amount, indicating a high level of market concentration. This suggests that the EU SAF market remains nascent and dominated by a few mature or well-capitalized players.

📌 SAF was delivered to 33 Union airports across 12 EU Member States, with 5 Member States – France, the Netherlands, Spain, Sweden, and Germany – accounting for 99% of the total amount supplied.

📌 According to Eurostat, the EU imported 80 kt of SAF in 2024, representing over 40% of the total EU SAF supply that year, highlighting the continued importance of imports despite the gradual growth of domestic production.

➡️ Source: European Union Aviation Safety Agency. ReFuelEU Aviation Annual Technical Report 2025

World Hydrogen Week

How will regulation, standardisation, and certification work together?

This question we discussed 09.10.2025 during the World Hydrogen Week in Copenhagen, organised by World Hydrogen Leaders.

Under the chair of Kim Talus and the moderation of Ulrike Hinz, together with Régis Prévost and Mohit Agrawal, we explored how standards and regulation interact in the production of hydrogen and hydrogen derivatives.

This topic is also part of my ongoing research at the University of Eastern Finland. Building on my previous studies, I shared several key points during the discussion:

📌 Different purposes: Regulations aim primarily at achieving greenhouse gas (GHG) emission reduction targets, while standards focus on ensuring safety and technical compatibility.

📌 Different approaches to blending: Regulations allow flexibility through book & claim or mass balance systems, whereas standards typically apply only to physical blending.

📌 Different consequences for non-compliance: Under regulatory frameworks, penalties or GHG payments may apply, while under technical standards, non-compliance simply means the fuel cannot be used.

It was a truly insightful exchange on how these frameworks can and must align to support the development of a global hydrogen economy.

Updates to the Hydrogen Acceleration Act

Bundesregierung beschließt Entwurf für Wasserstoff-Beschleunigungsgesetz

On October 1, 2025, the Federal Cabinet adopted the draft Hydrogen Acceleration Act to speed up the development of hydrogen infrastructure and reduce bureaucratic hurdles.

✅ Key highlights:

📌 Covers the entire hydrogen supply chain: production, import, storage, transport, and pipelines.

📌 Includes facilities for synthetic fuels to decarbonize shipping & aviation.

📌 Declares hydrogen infrastructure projects as overriding public interest, ensuring higher priority in approval decisions.

📌 Introduces clear deadlines, digitalized processes, and faster procurement.

📌 Simplifies regulations for natural hydrogen through amendments to the Federal Mining Act.

☑️ What next:

The Bundesrat and Bundestag will deal with the draft law.

➡️ Full draft law available here: Entwurf eines Gesetzes zur Beschleunigung der Verfügbarkeit von Wasserstoff und zur Änderung weiterer rechtlicher Rahmenbedingungen für den Wasserstoffhochlauf und weiterer energierechtlicher Vorschriften

➡️ Source: Aufbau der Wasserstoff-Infrastruktur wird schneller, digitaler und unbürokratischer – Bundesregierung beschließt Entwurf für Wasserstoff-Beschleunigungsgesetz

2nd Call for International Hydrogen Projects

Call for International Hydrogen Projects

📢 Federal Ministry for Economic Affairs and Energy launches 2nd Call for International Hydrogen Projects.

The Federal Ministry for Economic Affairs and Energy (BMWE), together with the Federal Ministry of Research, Technology and Space (BMFTR), has published the second call for funding under the guidelines for international hydrogen projects. The BMWE thus supports the use of German hydrogen technologies abroad and aims to prepare and implement import routes to Germany.

✅ Key points:

📌 German companies can submit project outlines until 18 December 2025.

📌 Funding supports the development of renewable hydrogen and its derivatives outside Europe, with a focus on industrial-scale production plants and accompanying research (e.g., feasibility studies).

📌 Special emphasis is placed on German SMEs – technology suppliers and project developers – to strengthen expertise abroad and open new markets.

📌 Up to €30 million per project may be granted (subject to budget approval until 2026).

📅 On 13 October 2025, an information event will provide details on funding opportunities and allow participants to ask questions.

➡️ Register here: Förderaufruf zur novellierten Förderrichtlinie für internationale Wasserstoffprojekte

The initiative contributes to shaping a global renewable hydrogen market and securing future import routes to Germany, while showcasing German hydrogen technologies internationally.

➡️ Source: Bundeswirtschaftsministerium veröffentlicht zweiten Förderaufruf der Förderrichtlinie für internationale Wasserstoffprojekte

Briefing Delegated act on low-carbon hydrogen

European Parliamentary Research Service. Briefing: Delegated act on low-carbon hydrogen

I dove into the European Parliamentary Research Service Briefing on the “Delegated Act on Low-carbon Hydrogen”.

✅ Key takeaways:

📌 The delegated act, adopted by the Commission on 8 July 2025, is the final missing piece of the EU’s hydrogen regulatory framework. Its was adopted by the Commission on 8 July 2025, pending scrutiny by the Parliament and the Council until 10 November.

📌 The delegated act does not create financial incentives or targets but provides much-needed regulatory clarity on what qualifies as low-carbon hydrogen, supporting cross-border trade, investment, and a future EU hydrogen market.

📌 Electrolysis via the grid is only eligible in countries with very low grid emissions (currently: France, Sweden, Finland). Elsewhere, PPAs will play a key role.

📌 Nuclear power: The delegated act does not include a specific methodology for producing low-carbon hydrogen from nuclear power plants. The Commission plans to launch a public consultation on a draft methodology for this production method in 2026.

📌 Blue hydrogen faces stricter requirements. LNG-related emissions must be calculated using a methane-intensity methodology by 2027/28, raising uncertainty.

📌 Production costs: CCS-based hydrogen remains cheaper in the near term, while electrolytic hydrogen is still challenged by high EU power prices.

📌 Imports: The same low-carbon criteria apply to non-EU producers; a region-specific GHG methodology could follow by 2028.

⚠️ Parliament had already stressed in 2021 that low-carbon hydrogen must be seen as a bridging technology in the short and medium term, but also called for a clear distinction from renewable hydrogen.

The upcoming months will show whether Parliament and Council accept this final building block of EU hydrogen regulation or send the Commission back to the drawing board.

➡️ Source: European Parliamentary Research Service. Briefing: Delegated act on low-carbon hydrogen

H2international magazine

H2international. Hydrogen Magazine

The H2international magazine now offers a free subscription to their English publication, which provides valuable insights and updates on hydrogen developments worldwide.

I hope this resource will be useful for those who want to stay up to date with the latest hydrogen news.

🔗 Free subscription link: https://www.h2-international.com/