Hydrogen distribution in the Netherlands: Addressing Ambiguities in the regulatory framework

Hydrogen is increasingly recognized as a key solution for decarbonizing the Dutch energy system, particularly within the industrial sector. A national hydrogen network is under development to serve the five major industrial clusters in the Netherlands. However, meeting the hydrogen needs of the industries outside these clusters, which are collectively known as “Cluster 6”, remains difficult. Regulatory unclarity and ambiguity around the hydrogen distribution infrastructure, including restrictions on distribution system operators (DSOs), compound these challenges. This study investigates the complex and evolving regulatory landscape for hydrogen distribution across Cluster 6 in the Netherlands using a two-step approach of Institutional Network Analysis (INA) and stakeholder interviews. Findings outline possible pathways for delegating distribution responsibilities in current and future regulatory frameworks while stakeholders report structural and outcome uncertainty, limiting their willingness to invest in hydrogen distribution initiatives. The research findings highlight the need for a more coherent regulatory and technical framework to support more effective development of physical hydrogen systems. Policy recommendations include clarification of distributor roles, targeted support mechanisms, and flexible regulations that can adapt to the rapidly developing hydrogen market. • INA unveils the complexities in Dutch hydrogen distribution rules and roles. • Stakeholders struggle with unclear mandates, TPA, and unbundling constraints. • Uncertainty stifles investment in smaller, decentralized industrial clusters. • Policy reforms clarifying funding and governance in regional H 2 projects are proposed.