Hydrogen networks 2026 to 2033: eight deadlines from WANDA, KOSMO, WasABi, the MsbG and the EU Gas Regulation

Eight deadlines from 2026 to 2033

If you operate a section of the hydrogen core network, you have four dates until mid-2027: the charge by 1 November, as a gas transmission operator the revenue information at year end, planned costs by 31 May and actual costs by 30 June. For balancing responsible parties, suppliers and metering point operators the work starts with the data platform in July 2027 and the balancing start on 1 January 2028. The EU dates in 2031 and 2033 set the frame that today's German rulings are already working towards.

All eight deadlines are adopted or written into law; none comes from a draft. Two values that those affected need are still missing: we have not found a published ramp-up charge for 2027 as of 27 October 2026, and the market area manager's page does not yet give interface specifications for the data hub.

Publish the 2027 core network charge by 1 November

Hydrogen core network operators publish the charge for 2027 by 1 November 2026 at the latest. That is operative paragraph 2 sentence 3 of the WANDA ruling of 6 June 2024, and paragraph 3 applies the rule expressly to the ramp-up charge, which replaces a cost-based charge while the amortisation phase runs. If the charge changes after 1 November, the publication has to be corrected without delay; once the calendar year it applies to has begun, any change is ruled out (paragraph 2 sentence 5). 1 November 2026 is a Sunday, and the ruling does not move the date to the next working day.

Since 14 July 2025 the level has been fixed: EUR 25.00 per kWh/h per year for a firm annual capacity product (GBK-24-02-2#4). Every year the operators adjust it for inflation. Since KOSMO of 12 December 2025, they multiply the current charge by the consumer price index of the previous year relative to that of the year before (KOSMO, paragraph 3); for 2027 that means the 2025 and 2024 indices. For 2026, Open Grid Europe published EUR 25.55 and gave 2.2 percent inflation for 2024.

Since KOSMO, the surcharges and discounts belong in the same publication (paragraph 2(e)): monthly products cost one twelfth of the annual charge times 1.33, daily products one 365th (366th in a leap year) times 3.38, interruptible capacity gets a 10 percent discount, and at exit points to storage a discount cancels the monthly and daily surcharges. WaKandA introduced these products for network access from 2028; where a core network operator offers them earlier, the KOSMO prices already apply (KOSMO, paragraph 8).

For suppliers, 1 November is the day from which they can price hydrogen offers for the next year with fixed transport costs. That is why we see the correction clause as the sensitive part: until 31 December the charge may still change, and every correction hits network customers who have already priced with the 1 November figure. A core network operator should settle before publishing who approves a correction and how network customers are told about it. The Federal Network Agency's first scheduled review of the ramp-up charge is due on 1 January 2028, then every three years (WANDA, paragraph 3).

Planned costs by 31 May, actual costs by 30 June

Core network operators send the Federal Network Agency their planned costs for the following year with the calculation basis by 31 May each year, and the costs actually incurred in the previous year by 30 June. For both, the WasserstoffNEV sets 30 September; KOSMO replaces these dates for the core network (paragraph 5) and extends the agency's decision period on planned costs from three to four months. If the documents are complete, the decision on planned costs is therefore due by the end of September at the latest, a good month before the charge is published on 1 November.

The calculation basis has to let an expert third party follow the costs without further information (Section 14(2) sentence 2 WasserstoffNEV). If it is incomplete, the review period only starts once everything has arrived (sentence 4). If the period ends without a decision, the costs as submitted count as approved (sentence 5). For actual costs the agency has 15 months (subsection 3 sentence 3); the difference between revenues and approved costs flows into a later calculation period as a surcharge or deduction (WANDA, paragraph 7(g)).

Only the core network gets the early dates. A municipal utility building a regulated hydrogen distribution network outside the core network keeps 30 September for both submissions, so an operator with both kinds of network runs two calendars. In its 2024 version, WANDA had set 30 June for both core network submissions. KOSMO applies with effect from 1 November 2025, and internal schedules still built on the old date have been out of date since.

WasABi: data platform in 2027, balancing from 2028

By 1 July 2027 the data exchange platform for hydrogen, also called the data hub in the ruling, has to be in place; it is tested with market participants until 1 January 2028, and from then on balancing follows WasABi. Ruling Chamber 7's decision of 27 October 2025 (BK7-24-01-014) puts the platform in the hands of the hydrogen market area manager. On 8 December 2025 the hydrogen transport network operators named Trading Hub Europe, and THE accepted on 12 December. THE launched the tender for the data hub on 15 April 2026; its own page now reports the procurement as completed.

All data exchange for hydrogen balancing runs through the platform. It brings together registration for network access contracts under WaKandA, the balancing group contract and access to the virtual trading point in one place (paragraph 7(a)), takes nominations and publishes the overall network balancing status. Connection is through a standardised application programming interface whose standard the market area manager sets; existing API standards of German market communication have to be taken into account (7(c)(ii)). The specifications have to reach market participants "at a reasonable time" before 1 July 2027 (7(d), our translation). No date for that is given.

For hydrogen network operators, the main change is the metering data chain. At final customers' exit points and at entry points from domestic production plants, measured values count; they have to be recorded every quarter hour and sent to the market area manager without delay (paragraph 2(b)(bb)). Obviously faulty values have to be detected automatically by the network operator, who supplies substitute values (2(e)) and delivers the final, calorific-value-corrected volumes at the latest after ten working days of the following month (2(g)). There are no tolerances, and balancing is continuous.

Balancing responsible parties receive their balance without delay, at least every 15 minutes. The market area manager continuously classifies them as helpers when their balance runs against the overall network status, or as causers when it points the same way; in hours in which the overall status crosses the edge of the green zone, helpers receive a bonus and causers pay a penalty (paragraph 5). Where no balancing energy is used, the penalty is based on the EEX HYDRIX index. We see balancing as the larger of the two WasABi deadlines: THE builds the platform, but every network operator has to deliver the quarter-hour values from its own network. The market area manager submits its first report on the balancing system by 1 April 2029 (paragraph 9). How WasABi works together with capacity booking is covered in our article on WaKandA and the booking platform.

Hydrogen meters only with a gateway connection

From 1 January 2028, new hydrogen meters may only be installed if they can be connected securely to a smart meter gateway. Section 20(3) MsbG extends to hydrogen what subsection 1 already requires for gas meters; the connection has to meet the state of the art set in the protection profiles and technical guidelines. It applies at installation. It does not cover meters already in place, and it does not require every hydrogen meter to be connected to a gateway straight away.

The rule applies to default and competitive metering point operators that run or want to take on hydrogen metering points. For them the deadline is a procurement question: framework contracts, stock and type approvals still running in early 2028 have to cover gateway-capable devices. Metering operators know reading via the gateway from multi-utility metering through the smart meter gateway. WasABi fits in: from the same day, balancing requires measured quarter-hour values at final customers' exit points.

Gas TSOs: revenue information before 1 January

Gas transmission system operators publish by 31 December 2026, and then every year before 1 January, the information under Annex I point 1 of the Gas Regulation on the methods, parameters and values used to set their regulated revenues. Ruling Chamber 9 decided this on 9 December 2025; the ruling bears the reference BK9-25/617. The duty concerns the natural gas network, not the hydrogen network: Article 7(8) of Regulation (EU) 2024/1789 expressly excludes Article 19 for hydrogen networks. It appears in this article because the core network goes back to a proposal by the gas transmission operators, and many of them keep both dates in the same annual plan.

Six data points from Annex I stay out because the ruling chamber classes them as commercially sensitive (paragraph 2): details of depreciation and data from which the regulated asset base could be derived. Everything else goes on the operators' websites in a freely accessible, downloadable, read-only and barrier-free document in German and English (paragraph 3). Gas distribution system operators are not covered; the ruling is addressed only to transmission system operators within the meaning of Section 3 no. 5 EnWG.

EU Gas and Hydrogen Regulation: 2031 and 2033

The two EU dates are a little over four and six years away, yet they already shape where the German rules are heading. From 1 January 2031, hydrogen network operators or the competent regulators publish complete information on tariff derivation, methodology and tariff structure (Article 66(2) Regulation (EU) 2024/1789). The regulation leaves open which of the two; Germany has not yet settled it.

From 1 January 2033, hydrogen networks are organised as entry-exit systems (Article 7(6)). Isolated networks covered by a derogation under Article 52 of Directive (EU) 2024/1788 can be exempted (Article 7(7)). From the same day, hydrogen transmission network operators meet the requirements that Articles 5 (separate regulated asset base), 10 (capacity allocation and congestion management) and 13 (balancing rules) set for transmission system operators, and publish tariffs for every network point on a platform run by the European Network of Network Operators for Hydrogen, ENNOH (Article 7(9)). Until a network code on capacity allocation applies, links to the tariffs on the operator's own website are enough.

Germany is ahead with WaKandA and WasABi: capacity booking through a joint platform, balancing groups and a market area manager arrive in 2028. Whether the German rules need another adjustment by 2033 depends on the EU network codes for hydrogen, none of which is in force yet. How the EnWG implements the package is set out in our article on the EnWG amendment for the gas and hydrogen package.

What applies if a deadline is missed

None of the eight deadlines carries its own fine. The WANDA, KOSMO, WasABi and BK9-25/617 rulings set no specific consequence; the regulator can order compliance under Section 65 EnWG and enforce it with coercive fines under Section 94 EnWG. For duties under Regulation (EU) 2024/1789, the Federal Network Agency performs the regulator's tasks and applies the procedural rules of the EnWG (Section 56(1) sentence 1 no. 2 EnWG). For hydrogen meters, the MsbG sets no administrative offence; the agency can order measures under Section 76 MsbG and enforce them with coercive fines (Section 76(4) MsbG).

More tangible are the effects built into the rules themselves. An incomplete calculation basis delays the start of the review period for planned costs, and without approved costs the basis for the charge on 1 November is weak. A core network charge cannot be changed after 1 January. This is a general classification by role, not an assessment of your individual case.

Criticism of the ramp-up charge and of balancing

The ramp-up charge has been disputed since it was set, because it has to recover costs until 2055 without putting off the first customers. On the day of the decision, the German Hydrogen Association (DWV) saw a "potentially deterrent effect" (ZfK, 14 July 2025, our translation). In the consultation, the German Steel Federation (Wirtschaftsvereinigung Stahl) had worked out that the charge is due at both entry and exit points:

The Federal Network Agency kept EUR 25. In December 2025 KOSMO added a storage discount that cancels the monthly and daily surcharges at exit points to storage; charging at both entry and exit points remains. On balancing, the criticism came from traders. EFET Deutschland wrote in the first WasABi consultation on 30 August 2024: "We are, however, concerned that cluster formation, indirectly through capacity restrictions, will lead to several market areas each with its own VHP" (our translation). VHP is the virtual trading point at which hydrogen is transferred between balancing groups. The ruling expressly allows clusters at the start of the ramp-up (paragraph 1). Whether that ends in one market area with one trading point or several depends on how the network is built out, not on the balancing rule.

What to do by mid-2027

Core network operators have two fixed dates in the next eight months, 1 November and 31 May. Balancing responsible parties and suppliers are preparing for an interface whose specifications are still pending, and metering point operators for a procurement rule from 2028. All deadlines with roles and systems are also in the energy transition deadline calendar.

Next steps by role

1. Publish the 2027 charge

   Core network operators: by Sunday, 1 November 2026, put the ramp-up charge, multipliers and discounts online and decide who approves a correction until 31 December.

2. Finish the Annex I document

   Gas TSOs: publish the document on regulated revenues, without the six excluded data points, by 31 December in German and English, accessible and read-only.

3. Move the calculation basis to May

   Core network operators: schedule annual planning, investment planning and cost forecasts so that the 2028 planned costs are complete and traceable for third parties on 31 May 2027, and the 2026 actual costs on 30 June. If you also run a distribution network outside the core network, keep 30 September for that one.

4. Prepare for the data hub

   Hydrogen network operators, balancing responsible parties and suppliers: clean up master data for entry and exit points, settle quarter-hour metering and automated plausibility checks at exit points, book test capacity for the second half of 2027, and wait for THE's API specifications before fixing your own formats.

5. Change procurement

   Metering point operators: require a secure gateway connection under Section 20 MsbG in tenders for hydrogen meters delivered from 2028.

Further reading

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