Enagás has reopened its Call for Interest until September 30th . This non-binding consultation asks the market how much hydrogen it expects to produce, consume, or sell, and uses these responses to adjust the size of the future Spanish Hydrogen Backbone Network. The process initially closed on June 30th with 128 companies and nearly 300 projects , but new European regulations on renewable energy have altered the conditions under which some of these stakeholders had calculated their demand.
The change comes with RED III , the third revision of the European Renewable Energy Directive. Among other measures, it introduces new targets for decarbonizing transport and progressively increases the share of so-called RFNBOs ( Renewable Fuels of Non-Biological Origin ). This category includes renewable hydrogen and fuels produced from it, provided they meet the criteria established by European regulations.
On the road, the sub-target for these fuels starts at 0.2% of the energy content in 2027 , increases to 2.5% in 2030 , and reaches 11% in 2040. The practical consequence is that certain operators will have to progressively incorporate these types of fuels or meet equivalent decarbonization targets, so some companies may need more hydrogen than they had anticipated when they initially responded to Enagás.
The review also comes at a time when the Spanish market is showing an increasingly visible gap between announced projects and the capacity that actually manages to move forward .
In 2026, Moeve made the final investment decision (FID) for the first 300 MW of Onuba ; Repsol approved 100 MW at Petronor , and bp and Iberdrola continued with 25 MW in Castellón . At the same time, NOON II and ODIN withdrew from the Spanish procedure associated with the European Hydrogen Bank, despite having passed previous competitive screenings.
“There was a bubble of expectations. When it started, around 2020, many people didn't really know what hydrogen was and expected much more than it could deliver. All of that has deflated significantly,” Marcos Rupérez , a consultant specializing in hydrogen and linked to the sector since 2009, told Energía Estratégica.
This adjustment changes the interpretation of the nearly 300 projects reported to Enagás . The figure allows for the identification of potential production and consumption needs, but it does not equate to 300 plants that will be built, nor to volumes already contracted. In recent months, even some of the developments that are progressing are doing so on a smaller scale than announced during the boom. Moeve maintains an ambition of up to 2 GW for the Andalusian Green Hydrogen Valley, but the first approved investment is concentrated at 300 MW, expandable later by another 105 MW.
“The remaining work is much smaller and more scattered than we imagined during the boom. There is more detailed engineering and specific projects, but on a much smaller scale,” Rupérez added.
“The difference between the projects that will be done and those that will not remains, fundamentally, that there is some kind of obligation on the part of the governments.”
The new European regulations introduce precisely this variable. Until now, a significant portion of future demand depended on industries voluntarily choosing to replace fossil fuels with renewable hydrogen despite its higher cost. RED III is beginning to transform part of that decision into a regulatory requirement, especially in activities related to fuels and transportation.
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The composition of the projects that progressed the most in 2026 shows where this transition can be easier. The 100 MW approved by Repsol at Petronor will primarily replace energy consumption within the refinery itself; the 25 MW in Castellón are being developed alongside a bp facility that already uses grey hydrogen , currently produced from fossil fuels; and Onuba is part of the Moeve industrial ecosystem in Huelva .
In these cases, the project does not need to create a completely new market: there is an existing facility that already consumes hydrogen and can progressively replace part of it with renewable production.
"In Spain, my impression is that the projects that will really move forward will mainly be those linked to oil companies, replacing the gray hydrogen they already consume with green hydrogen."
The difficulty increases when production and demand must appear simultaneously . An electrolyzer intended for new markets needs not only to build the plant, but also to find buyers willing to commit for years to paying for a product that is even more expensive than its conventional alternatives.
“Hydrogen is still not profitable. There is a gap between the cost of production and the price the market can pay in virtually all applications. And, in general, subsidies don't fully cover that difference either,” Rupérez warned.
Aid does not guarantee FID either
Support mechanisms attempt to bridge that gap. This year, Spain awarded €274.2 million to ATLAS, QUIXOTGEN, P-HYNET, and ZARAGOZAH2V, four projects totaling 102.27 MW , through a scheme that pays a premium for each kilogram of renewable hydrogen actually produced. However, the withdrawals of NOON II and ODIN before the final decision showed that receiving aid does not eliminate the need to secure financing, guarantees, and power purchase agreements.
This is the context in which Enagás is once again requesting data from the market. The issue is no longer simply about counting projects, but about knowing how much hydrogen will be produced, how much will be consumed, where those volumes will be located, and when a physical connection will be needed . These parameters determine the size of the pipelines, their route, and the construction schedule for an infrastructure that has already begun to move forward administratively.
On June 30 , Enagás requested authorization from the Ministry for Ecological Transition for the first four sections of the Spanish Hydrogen Backbone Network. The company plans to submit the remaining applications between the fourth quarter of 2026 and the first quarter of 2027. The planned system spans approximately 2,600 kilometers and will function as a large transport network, connecting areas where renewable hydrogen is produced with refineries, industries, and other consumption centers.
The infrastructure will also need to be linked to H2med , the European corridor designed to transport hydrogen from the Iberian Peninsula to France and, subsequently, to other markets on the continent. In this way, the Spanish network is designed not only to supply domestic consumption but also to channel some of the eventual production destined for export.
The Backbone Network itself emerged from a similar process. The 2023 Call for Interest brought together 206 companies and 650 projects , identifying the major production and consumption hubs that served as the basis for designing the infrastructure. Three years later, the market that will use it is more selective and focuses its decisions on applications with identified demand, while part of the original pipeline is reduced, delayed, or disappears.
The reopening until September 30 will allow Enagás to assess whether the new regulatory obligations reinforce demand and what portion of the nearly 300 registered projects maintain sufficiently firm needs to translate into transport capacity. For Enagás, the relevant data will no longer be how many initiatives remain on the map, but rather what volume will ultimately justify each section of the future network .