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ARTICLE · 28 APRIL 2026

Hydrogen Unbundling Regime Takes Shape

A&O Shearman
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In its draft law of April 20, 2026, the Federal Government is presenting its proposal to transpose the Gas and Hydrogen Directive (Directive (EU) 2024/1788) into national law.

GermanyEnergy and Natural Resources
Nicolaus Ascherfeld
Nicolaus Ascherfeld
Dr. Udo Herbert Olgemöller
Dr. Udo Herbert Olgemöller
Marie-Luise von Buchwaldt
Marie-Luise von Buchwaldt
Janina Müller
Janina Müller
Johann Von Pachelbel
Johann Von Pachelbel
Till Arne Storzer
Till Arne Storzer
Author LinkedIn connections

In its draft law of April 20, 2026, the Federal Government is presenting its proposal to transpose the Gas and Hydrogen Directive (Directive (EU) 2024/1788) into national law.

A core element of the proposed amendment is the adjustment and introduction of comprehensive unbundling provisions in the Energy Industry Act (Energiewirtschaftsgesetz, (EnWG)) for hydrogen infrastructure. The proposal closely mirrors the provisions on unbundling applicable to existing natural gas networks that have been in place since 2009. This approach is to be welcomed, as it is likely to enhance legal certainty in the upcoming procedures for the initial certification of hydrogen network operators.

1. Vertical unbundling of transmission system operators

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