A new Frontier Economics study for the Swiss Federal Office of Energy (SFOE) explores the regulatory conditions that may become relevant if Switzerland seeks to connect to the emerging European hydrogen network, offering insights that could also be relevant for other non-EU countries considering hydrogen links with the EU.
Hydrogen is expected to play a key role in Europe’s transition to a climate-neutral energy system. As the EU develops a dedicated hydrogen backbone, questions around cross-border infrastructure and regulatory alignment are becoming increasingly important – not only for Member States, but also for neighbouring third countries.
The study examines regulatory connection requirements for third countries
Our study considers regulatory aspects that may become relevant if Switzerland were to connect to the European hydrogen network. Particular attention is given to a possible hydrogen transit pipeline linking France, Germany and Italy through Switzerland.
Within the Union’s gas and hydrogen package, hydrogen connections with non-EU countries are addressed through provisions on the requirement of international or intergovernmental arrangements intended to support regulatory coherence, as set out in Art. 53(1) of Directive (EU) 2024/1788. Any such arrangements would, in practice, be subject to bilateral negotiation. Against this background, the study discusses the potential scope of such arrangements, how relevant EU provisions could be interpreted in practice, and which regulatory topics may become relevant in any future discussions.
Ten regulatory areas highlighted for consideration
Our analysis identifies ten regulatory areas that are likely to be pivotal in any agreement.
Figure 1 Overview of regulatory areas identified for consideration
A comparison between EU rules and approaches discussed in the Swiss context suggests that differences may be more pronounced in areas such as unbundling, third-party access, tariff framework, market area and the certification of renewable hydrogen. By contrast, broader alignment is expected with respect to the role of the regulator and certain aspects of network planning.
Informing future hydrogen integration
Overall, the study provides a structured framework to support policy discussions on cross-border hydrogen infrastructure. While the study is grounded in the Swiss context, its findings are relevant for other third countries seeking to connect to the European hydrogen network. In particular, the analysis illustrates:
- how EU provisions for hydrogen interconnectors with non-EU countries may be applied in practice;
- which regulatory issues are most likely to shape negotiations with the EU or individual Member States; and
- where third countries may retain flexibility for domestic hydrogen networks, and where closer alignment with EU rules is likely to be required.
By clarifying potential points of alignment and tension with EU regulation, it offers practical guidance for Switzerland and other third countries as they consider how best to integrate into the European hydrogen market. These insights may be especially relevant for countries that see themselves as transit hubs, importers or exporters of hydrogen to the EU.
Author
Senior Consultant
Senior Consultant
07 April 2026
