ACER criticises delays in receiving ENTSOG’s 2024 draft ten-year gas and hydrogen network development plan and recommends improvements

ACER publishes today its Opinion on the draft gas and hydrogen ten-year network development plan (TYNDP) 2024 submitted by the European Network of Transmission System Operators for Gas (ENTSOG) on 20 October 2025.

What is the TYNDP?

Every two years, ENTSOG publishes a TYNDP where it:

• identifies EU’s hydrogen infrastructure needs;

• assesses new infrastructure projects to ensure security of gas supply, market integration and competition. 

ENTSOG’s draft 2024 TYNDP provides a pan-European view on hydrogen infrastructure needs up to 2040, an assessment of the natural gas curtailments under various stress cases and lists promoters’ planned projects.

ACER’s role is to assess (in an Opinion to ENTSOG) the methodologies used in the TYNDP, its development process and outcomes as well as to provide suggestions for improvement.

ACER’s recommendations aim to support investment decisions and facilitate the efficient development of the European gas and hydrogen grid, in line with broader EU policy goals.

What are ACER’s main findings on the 2024 draft TYNDP?

ACER acknowledges several improvements:

• in the methodologies used for the TYNDP development;

• on how the Hydrogen Infrastructure Gaps Identification Report in the draft TYNDP reflects ACER’s  recommendations; 

• greater transparency regarding the technical information of the submitted projects; and

• clearer presentation of the results.

While recognising the complexity of the TYNDP process, ACER notes shortcomings:

• The late delivery of the 2024 TYNDP (submitted to ACER in Q4 2025) undermines the alignment with the selection of projects of common interest (PCIs) and projects of mutual interest (PMIs). PCIs and PMIs are both categories of cross-border energy infrastructure projects under the TEN-E Regulation. PCIs are located within the EU, whereas PMIs are between the EU and non-EU countries.

• Limited implementation scope: only one scenario of future possibilities was considered, and a cost-benefit analysis was conducted only for some projects.
• Insufficient data quality and transparency, including missing costs for many projects.

• Weak connection between Europe’s identified needs and the projects being proposed by project promoters.   

What are ACER recommendations? 

To finalise its 2024 TYNDP and prepare for future editions, ACER recommends ENTSOG to:

• Ensure a timely submission of the TYNDP by addressing the root causes of the recurring delays.

• Perform cost-benefit analyses for all scenarios and projects.

• Strengthen inputs, assumptions and cost data to ensure credible results.

• Improve transparency of project information and methodological choices.

• Make the plan needs-driven, with clearer justification for proposing the specific projects.

What are the next steps?

ENTSOG should take ACER’s recommendations into account to finalise the 2024 draft TYNDP and further improve its upcoming editions.