25.03.2026 - "The integration of hydrogen into the Energy Industry Act finally creates a unified legal framework for gas and hydrogen infrastructures. However, we miss further instruments in the draft law to encourage investments in the hydrogen ramp-up. A state-backed mechanism is necessary to secure the establishment of hydrogen distribution networks and storage facilities. Otherwise, these will not be built, and the networks will be too expensive for companies to connect.

Moreover, security of supply should be given the highest priority: Gas customers must be adequately informed in advance if connections will be refused or terminated in the future. Only then can they plan their transition to climate-neutral energy supply. The proposed ten-year information and cancellation period – complemented by the additional five-year period after plan confirmation – is reasonable and must not be shortened. The same applies to the deadline for concluding fossil gas deliveries beyond the year 2049, or 2044 for end-users. After all, companies may not be able to foresee for a long time which contribution gas usage with CCS/CCU or compensation projects will make to energy supply in the future. Against this background, the ban on comprehensive dismantling of the gas network is also appropriate.

However, the mere possibility of connection termination threatens to undermine investment readiness and push existing plants off the market once the EEG remuneration ends. This contradicts the European goals of increasing the share of renewable gases. Protective mechanisms are urgently needed to safeguard investments in biogas plants in particular.”