Connecting electrolyser to the electricity grid (as a consumer)

This LAP is concerned with formal procedures and arrangements via a responsible/legal authority for access to the e-grid (at a local or other level) for electrolyser connection and whether an electrolyser connection is treated differently to connection of a conventional electricity consuming load. If an electrolyser load is treated differently then the variance in procedures are sought to be identified


Permission (process) and additional restrictions regarding the connection of the electrolyser to the electricity grid.
Is it a barrier?
Type of Barrier
Regulatory gap
Assessment Severity
Regulatory gap according electrolysers.


Question 1 Which is the responsible authority/legal entity for connection of an electrolyser to the electricity grid?
It depends on the voltage level. If the connection is in High or Medium Voltage, the TSO REE is the authority. If the connection is in the Low Voltage side, the DSO is the authority to approve it. If problems appear during the authorization, they have to be solver firstly by the regional authorities. If the problem persists, is the National Commission of the Markets and Competition
Question 2 Connection procedure and requirements: Are the steps different between an electrolyser and any other connecting consumer-facility (e.g.: industrial installation of similar demand)?
As a load, the electrolysers have to follow the same procedure than other loads. It mainly consists on obtaining the access permit, and also the connection permit. This process is similar for the connection to the TSO or the DSO. There are also technical requirements for the connection which vary depending on the voltage, and also for the region where the connections takes place. Connection to High or High–Medium Voltage, is covered by the protocol “Descriptive guide to the Grid connection procedure”, where also some information about technical rules and related information to the TSO is added. Note that for this connection, the requirements and the loads are higher. For the connection to the DSO, each of them has different protocols to follow.
Describe the comparable technology and its relevance with regard to hydrogen
Consumer or industrial loads.

National legislation:

EU Legislation:

  • Directive 2009/72/EC of the European Parliament and of the Council of 13 July 2009 concerning common rules for the internal market in electricity
    Directive 2009/72/EC establishes common rules for the generation, transmission, distribution and supply of electricity, together with consumer protection provisions. It lays down the rules relating to the organisation and functioning of the electricity sector, open access to the market, the criteria and procedures applicable to calls for tenders and the granting of authorisations and the operation of systems. It also lays down universal service obligations and the rights of electricity consumers and clarifies competition requirements.

    Article 25 establishes the “Tasks of the distribution system operator” which include: ensuring the long-term ability of the system to meet reasonable demands for the distribution of electricity […] as well as to ensure that the system operator does not discriminate between system users or classes of system users including e.g. when setting rules for the charging of system users, etc. Article 25 allows, however to require the distribution system operator to give priority to generating installations using renewable energy sources or waste or producing combined heat and power.

    Article 32 sets the rules on “Third party access”: access to the transmission and distribution system, and LNG facilities shall be based on published tariffs, without discrimination between system users. The transmission or distribution system operator may refuse access where it lacks the necessary capacity. Duly substantiated reasons must be given for such refusal,
  • Commission Regulation (EU) 2016/1388 of 17 August 2016 establishing a Network Code on Demand Connection
    Regulation 2016/1388 establishes a network code which lays down the requirements for grid connection of:
    • transmission-connected demand facilities;
    • transmission-connected distribution facilities;
    • distribution systems, including closed distribution systems;
    • demand units, used by a demand facility or a closed distribution system to provide demand response services to relevant system operators and relevant TSOs.