IOGP Europe calls for simplification of the hydrogen regulatory framework through the Omnibus Package

We support the European Commission’s simplification agenda, as outlined in President von der Leyen’s Political Guidelines 2024–2029 and reaffirmed in the State of the Union on 10th September 2025, which underline that regulatory simplification is a central and urgent political priority for this Commission.

We also note the European Court of Auditors’ call for a revision of the EU Hydrogen Strategy and welcome the Commission’s willingness to engage in this process. The EU’s current regulatory framework for hydrogen, while ambitious in its intent, has become too complex and fragmented to effectively support the scale-up of a competitive hydrogen economy. Its prescriptive, technology-preferential approach - focused narrowly on renewable hydrogen - fails to reflect the full diversity of cost-effective and regionally suitable low-carbon hydrogen production pathways. As a result, it risks increasing the cost of decarbonization, slowing industrial transformation, and undermining Europe's energy and climate ambitions.

At a time when Europe’s global competitiveness is under pressure, companies urgently need a clear and credible signal that reducing regulatory burden is a top priority. The shift in focus across EU institutions toward competitiveness, simplification, and better regulation is a welcome development.

In this context, we call for the simplification of hydrogen-relevant legislation - particularly the Renewable Energy Directive (RED III), ReFuelEU Aviation Regulation, and the Gas Directive – through the Omnibus package.

Targeted modifications to these regulations would enable much-needed simplification, flexibility, and technological neutrality, including:

• Renewable Energy Directive (RED III)(2023/2413): Provide flexibility for reaching the renewable hydrogen industrial target by making it more technology-neutral, enabling different regions to take advantage of the most suitable
  hydrogen production pathways available, thus ensuring cost-effective and competitive hydrogen options for industry to contribute to EU climate goals effectively. Align the rules for recognizing CCS in third countries with the Lowcarbon Fuels Delegated Act.
• ReFuelEU Aviation (Regulation 2023/2405): Make synthetic low-carbon aviation fuels technology-neutral by ensuring that all fuels meeting the Low-Carbon Fuels (LCF) definition are eligible, irrespective of their energy source or production pathway.
• Gas Directive (Regulation 2024/1788): Introduce a grandfathering clause to protect Low Carbon Fuels projects past Final Investment Decision (FID) from disruptive future regulatory changes, thereby securing investor confidence and supporting sustained decarbonization.

These changes represent critical steps toward reducing regulatory burdens, unlocking investment, and accelerating the scale-up of clean hydrogen and sustainable fuels across Europe.

Download the document to find our more specific recommendations on how to achieve this.