Consultation on the ENNOH and ENTSOG report on de-risking options for hydrogen infrastructure

ENNOH and ENTSOG have published a joint report on de-risking options for investments in hydrogen infrastructure. The report follows on from a mandate from the Copenhagen Energy Infrastructure Forum 2025 to develop solutions for how cross-border hydrogen projects in particular can be financially secured and thereby accelerated.

The report takes as its starting point the central role of hydrogen for EU climate neutrality, security of supply and system flexibility. At the same time, market ramp-up has so far fallen short of expectations. Production and demand are still in the early stages of development, and pricing and regulatory frameworks are also only developing gradually. However, without reliable long-term capacity bookings, network operators can hardly make FIDs (Final Investment Decisions) for forward-looking infrastructure projects.

The report identifies three key risk categories, particularly for cross-border infrastructure:

Volume risk (infrastructure is built before demand materialises),
Price and regulatory risk (uncertain future hydrogen prices and willingness to pay), and
Additional cross-border risks arising from differing regulations and increased coordination requirements between Member States.

The report also analyses existing risk mitigation instruments, including:

intertemporal cost allocation (ICA) with an amortisation account,
government guarantees,
long-term capacity bookings,
network charge surcharges (‘dedicated charges’),
EU and national grants, and
cross-border cost allocation (CBCA).

ENNOH and ENTSOG conclude that no single instrument is sufficient to effectively address the structural revenue and investment risk of cross-border hydrogen projects.

As a possible EU-wide approach to minimising risk in the development of (cross-border) hydrogen infrastructure, the two organisations therefore recommend an ICA-based tariff approach with an amortisation account. This could be combined with a European special purpose vehicle (SPV) to coordinate payouts. In addition, an EU budget-backed guarantee is proposed as a safety net in case the market does not develop as expected. Furthermore, the report outlines a model for long-term capacity bookings, which could also be organised via a European SPV.

Without such a European framework, the report concludes, the expansion of cross-border hydrogen infrastructure risks falling behind the timeline required to meet the EU’s climate and energy targets.

The consultation on this report, which runs until 7 April, aims to gather stakeholders’ views on the relevance of the individual chapters and instruments. The feedback will be incorporated into the revision of the report before it is presented at the Copenhagen Energy Infrastructure Forum.

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