Certification Gap Analysis for Normal-Category and Large Hydrogen-Powered Airplanes

The transition to hydrogen as an aviation fuel, as outlined in current decarbonization roadmaps, is expected to result in the entry into service of hydrogen-powered aircraft in 2035. To achieve this evolution, certification regulations are key enablers. Due to the disruptive nature of hydrogen aircraft technologies and their associated hazards, it is essential to assess the maturity of the existing regulatory framework for certification to ensure its availability when manufacturers apply for aircraft certification. This paper presents the work conducted under the Clean Aviation CONCERTO project to advance certification readiness by comprehensively identifying gaps in the current European regulations. Generic methodologies were developed for regulatory gap and risk analyses and applied to a hydrogen turbine aircraft with non-propulsive fuel cells as the APU. The gap analysis, conducted on certification specifications for large and normal-category airplanes as well as engines, confirmed the overall adequacy of many existing requirements. However, important gaps exist to appropriately address hydrogen hazards particularly concerning fire and explosion, hydrogen storage and fuel systems, crashworthiness, and occupant survivability. The paper concludes by identifying critical areas for certification and highlighting the need for complementary hydrogen phenomenology data, which are key to guiding future research and regulatory efforts for certification readiness maturation.