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, COβ, and Power-to-X technologies in the EU, Germany, and the US
The European Commission has started the public consultation to evaluate the operations of the Innovation Fund by 2025.
π Form of Feedback – the online questionnaire via this link
π Feedback period – 15 April 2025 – 08 July 2025
β What is the Innovation Fund?
π The Innovation Fund is one of the worldβs largest funding programmes for the deployment of net-zero and innovative technologies.
π 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.
π 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.
π 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 Fundβs 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 EUβs 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 Commissionβs intervention over what could reasonably have been expected from national actions.
First analysis of hydrogen lobbying processes in EU policy-making.
First mapping of hydrogen lobbyists at EU-level.
β Some takeaways:
π The actual depth of the hydrogen economy will result not only from technological competition, but also from political decisions β for Europe, in particular, EU regulations and policies.
π It can be expected that the integration of hydrogen into the energy system will be a highly politicized process, with various actors trying to influence the transition in their own interests, as has been observed in other fields of the energy transition.
π European business lobbying often takes place through and by associations, which have established channels of access to political decision-makers. The European Commission, in particular, favors associations as contact partners because an aggregation of individual actors reduces the transaction costs of coordination.
π Corporate lobbying in the EU traditionally takes place through a multi-level chain of representation: Companies join national trade associations, which in turn are members of the corresponding associations at EU level. However in recent years, direct lobbying by individual companies at EU level has increased significantly.
π The membership structure of European hydrogen associations shows that hydrogen is supported by a wide range of economic sectors and actors, but in particular by mid- and downstream natural gas companies, large chemical companies, car manufacturers, and manufacturers of machinery, electronic and electrical equipment.
π The most well-known key factors influencing lobbying activity are material resources, such as lobbying budget or lobbying staff. Organizations with greater resources, regardless of other characteristics, are more likely to gain access to European decision makers.
π Characteristics of the hydrogen stakeholder population:
47.28 % – companies
35.94 % – trade associations
5.72 % – NGOs
π Geographical distribution of hydrogen stakeholders:
Most of the stakeholders (467; 74.60 %) are primarily organized at the national level.
139 actors (22.20 %) are primarily organized at the EU level and a small portion of 20 actors (3.20 %) represents interests organized at the international level.
Among the stakeholders organized at the national level, 410 (87.79 %) are based in EU Member States.
The most frequently represented non-EU countries are the United States, the United Kingdom, Norway and Switzerland. Germany is best represented with 166 actors (24.84 % of the total).
π the SAF flexibility mechanism allows an aviation fuel supplier to supply the minimum shares of SAF as a weighted average over all the aviation fuel it supplied across all EU airports for each reporting period.
π the SAF flexibility mechanism is intended to give the SAF industry sufficient time to scale up its production and supply capacities.
π this means that aviation fuel suppliers may supply aviation fuels containing higher shares of SAF in certain EU airports to compensate for aviation fuels containing zero or lower shares of SAF in other EU airports.
π The SAF flexibility mechanism applies from 1Β January 2025 until 31Β December 2034.
β Some key conclusions from SAF flexibility mechanism report:
π Compliance with targets:
Aviation fuel suppliers can claim the supply of SAF for the purposes of complying with their ReFuelEU Aviation obligations and contributing to the national RED targets.
EU law does not prevent a batch of SAF to be certified under more than one certification scheme (e.g. RED, CORSIA certified fuels).
Aircraft operators can claim the use of a given quantity of SAF under one GHG reduction scheme, including the EU ETS and ICAOβs CORSIA.
π Virtual trading of SAF sustainability certificates
there is no unified industry-wide position neither on the design or the necessity of implementing such an accounting mechanism system for the purposes of complying with current blended SAF obligations and of claiming their use under other pieces of EU law, such as the EU ETS that does not allow aircraft operators to claim the use of blended SAF without physically delivery.
virtual trading of SAF sustainability certificates may bring new dynamics to the market on the demand side, but it is not clear whether this would have any real impact on the production side at this early stage.
π Availability of blended SAF at EU airports
the risk of a significant geographic concentration of blended SAF in few EU airports is limited.
most aviation fuel suppliers operate only within the borders of their respective Member State, so the possibility of significant geographic concentration is already largely limited to national markets.
many EU airport managing bodies have clearly communicated their intention to make blended SAF available in the coming years on their premises.
projects for new SAF capacities are appearing in various locations across the EU.
On 9 April 2025, the German political parties published their coalition agreement.
β Parties of the agreement:
CDU/CSU – the Christian Democratic Union of Germany / Christian Social Union
SPD – the Social Democratic Party of Germany.
βοΈ What is a Coalition Agreement:
is an agreement between the parties that form a coalition government.
identifies the most important shared goals and objectives of a new government.
is legally not binding for Parliament.
β‘οΈ The Coalition Agreement is available via this link
β Hydrogen in the Coalition Agreement:
π Hydrogen economy:
climate-friendly hydrogen from various sources.
the long-term goal is to transition to climate-neutral hydrogen from domestic production and imports.
π Reduction of Overregulation:
to advocate for pragmatic national and European regulations and their rapid implementation.
overregulation must be reduced.
π Hydrogen Production:
through large, system-supporting electrolysis plants; and
increasingly in a decentralized and nationwide manner.
π Hydrogen Import:
to consistently expand energy partnerships and the cross-border and necessary domestic infrastructure for imports of hydrogen and its derivatives in all directions.
this includes connections to all German and European ports.
π Hydrogen Funding:
to utilize national and European funding instruments, such as H2 Global, IPCEI projects, and specific programs for SMEs.
π Hydrogen Infrastructure:
the hydrogen core network must connect industrial centers throughout Germany, including in southern and eastern Germany.
hydrogen storage facilities must also be taken into account.
the financing conditions must ensure that the core network is implemented and the distribution network is also developed in an integrated plan.
In this episode of Clean Energy Talks video blog with Khrystyna Kasyanova, a Green Hydrogen Business Development Manager at RP Global, we talk about hydrogen offtake agreements in the EU and globally:
What is the current state of the hydrogen sector?
What actions have you taken to identify potential offtakers?
Where do you see the highest potential for green hydrogen?
How can the price gap between grey hydrogen and green hydrogen be overcome?
What actions would you recommend to companies aiming to secure green hydrogen offtake agreements?
β‘οΈ Reach out here on LinkedIn or contact me for more details on the video topic.
In this episode of Clean Energy Talks video blog with Francesco Tonci Ottieri della Ciaja, the Founder of IndHex, we talk about the development of the hydrogen market by answering these questions:
What is the current state of the hydrogen market?
What is the general mood in the hydrogen market?
Hydrogen targets and hydrogen project development: is it feasible to achieve all the hydrogen targets in the EU?
Hydrogen prices: What are the main challenges related to hydrogen prices?
β‘οΈ Reach out here on LinkedIn or contact me for more details on the video topic.
In this episode of Clean Energy Talks video blog with Carlos Bernuy-Lopez, a Senior Consultant and Thought Leader at Ramboll, we talk about electrolysis technologies by answering these questions:
Why does electrolytic technology still dominate?
Are there any differences in the production of hydrogen from nuclear and renewable electricity using electrolysers?
Is there still room for innovation and research and development (R&D) projects in this area?
What advantages and disadvantages of the electrolysis technology should we consider?
Can the EU secure a supply of these materials for electrolysis technologies?
When considering electrolysis technologies for hydrogen projects, what capital expenditures (CAPEX) can be expected?
Which types of electrolysis technologies are the most efficient?
β‘οΈ Reach out here on LinkedIn or contact me for more details on the video topic.
In this episode of Clean Energy Talks video blog with Beau Broen, Project Manager Hydrogen of New Energy Coalition, we discuss decentralized and centralized hydrogen production by answering these questions:
Where can we use a decentralized approach for hydrogen production?
What are the cost differences between centralized and decentralized hydrogen production?
Are there any differences in project complexity between centralized and decentralized production pathways?
Are there any bottlenecks for decentralized production?
Are there any improvements in permitting processes on the national (local) levels for hydrogen projects?
β‘οΈ Reach out here on LinkedIn or contact me for more details on the video topic.
In this episode of Clean Energy Talks video blog with Flore de Durfor, Founder & Managing Director of Atmen, we simplify the complexities of hydrogen certification and discuss how producers can navigate the certification process more easily by answering these questions:
Why is hydrogen certification so complicated?
What challenges do producers face on the way to certification?
How can technology make certification easier?
What does “certification readiness” mean for producers?
How do we begin preparing for hydrogen certification?
β‘οΈ Reach out here on LinkedIn or contact me for more details on the video topic.