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
Structural barriers, Economic barriers, Regulatory gap
Assessment Severity
The time and cost impact is similar to other e–grid connections. It may be implied that there is high potential and emerging interest for CHP as there are high levels of harmful emissions from domestic and industrial heating applications. The Bulgarian targets for reduction of harmful emission and the plans for building of HRS / increase in the demand for energy from RES for the transport sector are in line with the introduction of electrolyses from RES.


Question 1 Which is the responsible authority/legal entity for connection of an electrolyser to the electricity grid?
The local electric distribution companies (there are three such companies operating in Bulgaria – in three territorial units). At this stage the end user cannot choose but has to connect to the one where his location is. The National Electric Company has signed contracts with the three electric distribution companies.
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)?
At this stage there are adopted procedures from the rules and regulations for the other facilities – wind, solar and hydro plants
Question 3 If yes to question 2, what are the procedural steps to undertake to obtain the permission to connect the electrolyser to the electricity grid?
The procedure follows the regulations of the Spatial Development Act, the Law for Energy from Renewable Energy Sources and the Law on Energy; Nevertheless, certain difficulties may be faced when establishing a connection to the electric grid which may be a subjective matter sometimes.
Describe the comparable technology and its relevance with regard to hydrogen
It may be compared to energy from RES (such as hydro, wind and solar). Solar is widely used for micro–CHP based on batteries. There are companies offering such installation in the country (corresponding in powering function to hydrogen micro–CHP). There are larger facilities that used an energy mix (from solar and wind) for small industrial applications (20–100 kW). Most often that is supplied for self–consumption. Up to 30 kW there are simplified procedures in place.

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.