ACER encourages ENTSOG to further improve the methodology for identifying hydrogen infrastructure gaps

ACER encourages ENTSOG to further improve the methodology for identifying hydrogen infrastructure gaps
What is it about?
ACER releases today its Opinion on the hydrogen Infrastructure Gaps Identification (IGI) report 2024. ACER welcomes the publication of this report prepared by the European Network of Transmission System Operators for Gas (ENTSOG), providing recommendations to improve the underlying methodology.
What is the hydrogen Infrastructure Gaps Identification report?
Hydrogen is expected to play a key role in achieving the EU’s climate and energy goals. However, its market is still in the early stages, with low renewable hydrogen production and consumption, and slow infrastructure buildout. High production costs and uncertain demand are hindering market development. Unlike electricity, hydrogen also lacks a well-developed transmission network, making infrastructure planning more complex and highly dependent on policy support and demand forecasts.
To address these challenges and support coordinated planning and investments, ENTSOG published the first hydrogen Infrastructure Gaps Identification report in March 2025. This report is part of the EU’s Ten-Year Network Development Plan (TYNDP) framework and aims to identify regional gaps in hydrogen infrastructure based on demand and supply projections for 2030 and 2040.
What does ACER recommend?
While ENTSOG’s report highlights bottlenecks that could signal potential infrastructure shortages, ACER recommends improving the methodology used to better identify these gaps by:
Incorporating scenario variants to understand how projected infrastructure needs change under different assumptions. This would help identify the risk of investments that do not align with future hydrogen demand.
Refining the analysis to better determine where and how much additional cross-border infrastructure capacity is needed.
Seeking a more cross-sectoral modelling approach to capture the interdependencies between hydrogen infrastructure and electricity systems more effectively.
What’s next?
ACER encourages ENTSOG to start testing the suggested improvements using the data currently available, without waiting for the upcoming 2026 TYNDP scenarios. Early testing can help enhance the methodology used to identify future needs, prevent delays and reinforce trust in the ensuing results.