Initially, the lawmakers intended to reassess the rules in July 2028, pushing back against criticism.

However, the RFNBO rules review has now been fast-tracked due to complaints by Member States and the industry regarding both the complexity of the 2023 rules and the stringency of their requirements.

Separately, by the end of June 2026, a public consultation will be launched on draft methodology to recognise alternative approaches for low-carbon electricity from nuclear power plants.

While the Commission has not yet commented on likely changes in the legislative framework, earlier calls by EU countries and the industry might provide additional context.

In April this year, five EU countries, including Germany and Spain, sent a letter to the Commission (seen by Veyt) requesting relaxed RFNBO production rules stating that existing framework constrains market development today. Specifically, they requested:

• postponement of the additionality requirement until 2035;

• extension of monthly correlation beyond 2035 (“for countries/regions with relatively clean electricity systems, treating the EU as one whole region”); and

• reduction of the threshold for counting grid electricity as fully renewable (current set at 90 %)

Under the current rules, monthly matching applies until the end of 2029, tightening to hourly thereafter. RFNBO installations coming online before January 2027, are exempt from the additionality requirement until 2038, while those coming post-2027 need to ensure that power plants come into operation no earlier than three years before the RFNBO installation.

Back in 2024, German Economy Minister Habeck sent a letter to the European Commission requesting a relaxation in the RFNBO production rules. The letter also suggested postponing the additionality phase-in period to 2035 instead of 2028 and extending monthly temporal matching to the end of 2030. Fast forward to 2026, French President Emmanuel Macron declared that it was necessary to “simplify the hydrogen regulation” to have a “simple hydrogen regulation at the European level” based on “technological and energy neutrality”.

Market impact

The European Commission’s target of 10 Mt of domestic hydrogen production by 2030 is out of reach: in 2024, 29 kt was produced, while electrolyser capacity reached 308 MW. Including capacity under construction brings the active pipeline capacity to 2.3 GW in 2027.

Most of the hydrogen in the EU is produced via steam methane reforming (89 %), and only 0.5 % – through electrolysis.

This reality check alongside multiple calls from the industry and EU member countries have likely pushed Brussels to accelerate the timeline to reopen the rules.

It should also be noted that the hydrogen market development is slowed down by tardive Renewable Energy Directive (RED III) transposition that sets sectoral hydrogen consumption targets (share-based, not volumetric). Thus far, only a few countries have transposed RFNBO-related provisions, including Denmark, Germany and Ireland.

Third European Hydrogen Bank auction

During the third Hydrogen European Auction in May 2026, the Commission selected nine hydrogen production projects across seven countries in the EEA (see below). The auction awards successful projects with a subsidy to help cover the difference between hydrogen production costs and the market price.

The premia asked this time were higher than in the previous two auction rounds, likely reflecting bankability concerns and the thinning of the lower-cost Iberian pipeline. Together, these projects are expected to install 1.1 GWel and produce over 1.3 Mt of hydrogen over their first 10 years of operation. They will need to reach financial close within two and a half years of grant signature and enter into operation within five years. Agreements are expected to be signed in Q4 2026.

This brings renewable hydrogen production output from the three European Hydrogen Bank auctions to 2.9 Mt.

GO market implications

Veyt believes that the 2030 domestic RFNBO output in the EU would be markedly lower (below 1.5 Mt) than the Commission’s 10 Mt target, given the challenges that the hydrogen market is facing. This led to a revision of one of the underlying assumptions of our flagship long-term forecast – Veyt’s base case (VBC). With lower electrolyser capacity assumptions and consequently decreased power consumption (e.g. 57.4 TWh by 2030), the RES-E GO demand from the hydrogen sector dropped sharply, leading to lower GO prices compared to the previous VBC. Read more about this here.

Extending temporal correlation on monthly level beyond 2030 would allow the GO market to evolve more gradually to put in place the digital infrastructure needed to transition to hourly timestamping.

While postponing the additionality clause would simplify RFNBO production, it could at the same time lead to crowding out, where multiple market players compete for the same renewable volumes. However, since the projected electricity demand from hydrogen producers is likely to be lower than the Commission-estimated 500 TWh by 2030, this effect should be constrained.

Still, power consumption from RFNBO producers is expected to support GO demand long-term as RES-E GOs are required to prove renewable power consumption to certify produced hydrogen as fully renewable.

N.B. The current wording of the RFNBO Delegated Act does not specify whether geographical matching obligation applies to RES-E GOs i.e. whether they need to be sourced from the same/interconnected bidding zone.