Federal Government Proposes Hydrogen Unbundling Amendments in Draft Law
The Federal Government's draft law, presented on April 20, 2026, aims to align national regulations with the EU Gas and Hydrogen Directive. Key provisions include enhanced unbundling requirements for hydrogen infrastructure, mirroring existing natural gas regulations to foster legal clarity for operators.

The draft law proposes significant unbundling measures under the Energy Industry Act for hydrogen infrastructure, mirroring regulations in natural gas that have been effective since 2009. Operators of hydrogen transmission networks must now unbundle from vertically integrated companies, defined as those also engaged in hydrogen production or supply.
The legislation introduces horizontal unbundling, requiring legal independence from other transmission operators, while still permitting joint operations for efficiency. Exceptions apply to hydrogen distribution networks with fewer than 100,000 customers. The draft, entering the legislative process, is expected to enhance legal certainty and necessitate strategic planning for companies operating in both sectors.




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