Permission to connect/inject

This LAP concerns the permitting framework and processes required to be followed for hydrogen injection into the high pressure transmission gas grid at the TSO level, along with technical requirements for and oversight of local grid connections


Permission and additional restrictions regarding connection points for hydrogen compared to natural gas connection points.
Connection: “Network connection” refers to the connection of the hydrogen generating plant to the existing gas supply network, the link to the connection point of the existing gas supply network, the gas pressure control measuring system, the means for increasing the pressure and the verifiable measurement of the hydrogen to be fed.
Injection: Gas grid access (injection) is the system under which market players are allowed to use capacity in a pipeline, network, gas store or other gas facility.
The injection installation is part of the connection facility
Is it a barrier?
Type of Barrier
Structural barriers, Regulatory gap
Assessment Severity


Question 1 What is your legal situation (requirement from legislation and administrative procedures) with regard to international interconnection for the injection in the gas grid with neighbouring countries?
The answer to this question is not clearly available now from a regulation point of view. The interconnections in Spain are with the European Union and Africa. Due to it, the charachteristics should be similars, and due to it, the quantities of hydrogen should be stable among the different countries.
Question 2 Is it possible for a TSO to refuse to feed in hydrogen from neighbouring countries at cross-border interconnection points? b - Can you have a differentiated treatment (i.e.: applying a more stringent threshold than the one applying under your national law?
Rules to facilitate the entry of new gas providers on the market and the access to the transport capacities available have been proposed at a European level. Since the 1 january 2016 these HAR (Harmonized Allocation Rules) are under application at the national interconnection points with the grids of the bordering countries. These rules focuses essentially on the exchange capacities exchanged internationally.
Question 4 Connection to the gas grid of a hydrogen producing facility b - Is required to conclude a connection agreement and if yes, what are the requirements for conclusion of a gas grid connection agreement: i. Connection assessment by the TSO ii. Assessment of grid compatibility by TSO iii. How much time does it take to conclude a connection agreement
b - i. – NA ii. – NA iii. – NA
Question 5 Grid access (injection into grid) Is it required to conclude a feed-in agreement (grid access contract) between DSO/TSO and H2 supplier? a - Is a TSO obliged to feed-in the H2; can a TSO deny the injection and under which conditions?
a - NA
Question 5 Grid access (injection into grid) Is it required to conclude a feed-in agreement (grid access contract) between DSO/TSO and H2 supplier? b - Are there requirements for a TSO to ensure a minimum feed- in capacity?
b - NA
Question 5 Grid access (injection into grid) Is it required to conclude a feed-in agreement (grid access contract) between DSO/TSO and H2 supplier? c - Are there requirements (technical) for the supplier of H2 (or for the supplied H2)?
c - NA
Question 7a - Please describe which party is responsible for delivering which part of the connection? For example is the TSO only responsible for delivering a connection point?
a - NA
Question 7b - Who can do the connection work (professional skills requirement)?
b - NA
Question 7c - Which party is responsible for carrying out the planning and establishment of the grid connection?
c - NA

National legislation:

EU Legislation:

  • Directive 2009/73/EC concerning common rules for the internal market in natural gas
    Directive 2009/73/EC establishes common rules for the transmission, distribution, supply and storage of natural gas.

    Its provisions and obligations apply to Hydrogen Gas by virtue of Article 1 (2), which states that the rules established by this Directive for natural gas, including LNG, shall also apply in a non–discriminatory way to biogas and gas from biomass or other types of gas in so far as such gases can technically and safely be injected into, and transported through, the natural gas system.

    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 gas […];shall provide any other distribution, transmission, LNG, and/or storage system operator with sufficient information […] as well as to ensure that the system operator does not discriminate between system users or classes of system including, including e.g. when setting rules for the charging of system users, etc

    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, applicable to all eligible customers, including supply undertakings, and applied objectively and without discrimination between system users.
  • Regulation 715/2009 on conditions for access to the natural gas transmission networks
    Regulation 715/2009 sets non-discriminatory rules for access conditions to (a) natural gas transmission systems; (b) LNG facilities and storage facilities taking into account the special characteristics of national and regional markets

    To achieve this, it sets harmonised principles for tariffs, or the methodologies underlying their calculation, for access to the network, but not to storage facilities, the establishment of third-party access services and harmonised principles for capacity-allocation and congestion-management, the determination of transparency requirements, balancing rules and imbalance charges, and the facilitation of capacity trading.
  • Regulation (EC) No 713/2009 of the European Parliament and of the Council of 13 July 2009 establishing an Agency for the Cooperation of Energy Regulators
    Article 1 Project matter and scope
    This regulation aims at:
    (a) setting non–discriminatory rules for access conditions to natural gas transmission systems taking into account the special characteristics of national and regional markets with a view to ensuring the proper functioning of the internal market in gas;

    Article 8 “Tasks as regards terms and conditions for access to and operational security of cross border infrastructure
  • Commission Regulation (EU) 2015/703 of 30 April 2015 establishing a network code on interoperability and data exchange rules
    The network code on interoperability aligns the complex technical procedures used by network operators within the EU, and possibly with network operators in the Energy Community and other countries neighbouring the EU.Article 7, Measurement principles for gas quantity and quality. In addition to interconnection points, Article 17 shall apply to other points on transmission network where the gas quality is measured. Article 18 shall apply to transmission systems. This Regulation may also apply at entry points from and exit points to third countries, subject to the decision of the national authorities.