Hy24

Hy24

Hy24 is convinced of the potential of hydrogen as a low-carbon energy carrier, and is financing large-scale projects that have a sustainable impact on the economy and society and offer the greatest returns.

Lobbying Activity

Meeting with Pascal Canfin (Member of the European Parliament)

27 Oct 2025 · IAA

Meeting with Kurt Vandenberghe (Director-General Climate Action) and Stegra (formerly H2GS AB)

15 Oct 2025 · Innovation Fund project implementation update

Response to Extension of the scope of the carbon border adjustment mechanism to downstream products and anti-circumvention measures

25 Aug 2025

Hy24s portfolio companies have more than 5 GW of electrolysis capacity in advanced development stages across multiple EU countries. As such, we firmly support the EUs strategic imperative to accelerate the transition to a clean, hydrogen-powered industrial sector. The EU, leveraging its technical leadership and robust investment in renewable hydrogen, is positioned to drive industrial decarbonization, enhanced security, increased strategic autonomy and sustainable economic growth. Europe has gained a significant head-start in the adoption of renewable hydrogen for the refining and steelmaking sectors and, with the right policy measures, can achieve similar success in the fertilizer and chemical sectors which are also well positioned to adopt the use of renewable hydrogen as a replacement to fossil fuel-based feedstocks. For these reasons, Hy24 fully supports the CBAM as a key enabler of the EUs twin industrial and decarbonization agendas and fully supports the initiative to expand its application to downstream products. Additionally, as the pursuit of decarbonization and the adoption of renewable energy are distinct, but inter-related policy objectives, we believe that the CBAM could also be used as a basis or as inspiration for a carbon leakage protection mechanism that works in synergy with the renewable energy obligations enshrined in the Renewable Energy Directive, in particular those associated with the adoption of renewable hydrogen in industrial sectors (Article 22(a) In the context of this public consultation, Hy24: Fully supports the extension of CBAM to downstream and additional products at risk of carbon leakage Proposes delegating power to the European Commission to address circumvention and diversion of CBAM obligations in an agile, fast and effective manner. Proposes extending the scope of CBAM to cover renewable energy content in addition to carbon intensity, in particular importers (i) nitrogen-based fertilizers, (ii) methanol and (iii) iron (HBI) and steel produced via direct reduction of iron imported in the EU should be obligated to demonstrate that a minimum share of RFNBO has been embedded in the manufacture of those product, in a manner coherent with the obligations imposed on EU producers by the Renewable Energy Directive (Article 22a) Proposes implementing an Indirect Cost Compensation mechanism for products downstream of CBAM covered products
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Response to Industrial Decarbonisation Accelerator Act

8 Jul 2025

Hy24 is the worlds largest investment platform dedicated exclusively to clean hydrogen. The firm manages two primary funds: A 2 billion infrastructure fund supporting the large-scale deployment of hydrogen production, distribution, and consumption projects. A second, smaller fund focused on investments in technology companies throughout the clean hydrogen value chain. Hy24 is deeply committed to advancing clean industrial transformation across the European Union. With more than 5 GW of electrolysis capacity in advanced development stages across multiple EU countries, Hy24 is actively enabling the decarbonization of key industrial sectorsincluding steel, chemicals, fertilizers, and refiningas well as supporting the transition to low-carbon transport solutions in maritime and aviation. As a sustainable investor managing private equity funds with the dual objectives of climate change mitigation and long-term economic value creation, we fully endorse the EUs vision for a clean, climate-neutral industrial sector. However, the continued success of these initiatives depends on the EUs sustained commitment to robust climate regulations. We appreciate the opportunity to provide feedback on the Industrial Decarbonization Accelerator Act. We strongly welcome this initiative and hope that regulatory advancementssuch as those proposed in the Actwill reinforce and complement existing EU policies aimed at achieving carbon neutrality by 2050. The path to a clean, climate-neutral industrial sector is not only the most responsible option for the European Unionit is the only viable strategy for securing long-term competitiveness, energy sovereignty, and global leadership in a rapidly decarbonizing world. Renewable hydrogen stands at the heart of this transformation. Its integration into the production of steel, fertilizers, chemicals, and methanol offers a unique opportunity to simultaneously advance decarbonization, foster sustainable economic value, and enhance energy security. By leveraging its technical edge and robust investment ecosystem, the EU can solidify its position as a global pioneer in clean industry. However, realizing this vision requires more than technological innovation and investment. It demands a regulatory environment that rewards sustainability, ensures a level playing field, and protects against carbon leakage. The Industrial Decarbonization Accelerator Act represents a pivotal opportunity to complete the EUs regulatory framework by: Establishing clear, enforceable obligations for embedding renewable hydrogen in key industrial products, applicable equally to domestic and imported goods. Implementing an EU-wide system of tradable RFNBO certificates to streamline compliance, reduce administrative burden, and enable cost-effective decarbonization across Member States. Ensuring robust enforcement and meaningful penalties to drive compliance and maintain he integrity of the market. By putting these mechanisms in place, the EU will unlock its market as a secure, attractive destination for near-zero industrial products, catalyzing further investment and innovation. Moreover, this leadership will set a global benchmark, encouraging the adoption of similar measures worldwide and accelerating the transition to a sustainable industrial future. In sum, a bold and comprehensive approachanchored by the Industrial Decarbonization Accelerator Actwill not only secure Europes industrial competitiveness, but also ensure that the EU remains at the forefront of the global transition to a clean, resilient, and prosperous economy.
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Meeting with Kamil Talbi (Cabinet of Commissioner Dan Jørgensen)

13 Mar 2025 · Hydrogen

Meeting with Jozef Síkela (Commissioner) and

5 Dec 2024 · The development of the hydrogen industry

Meeting with Kurt Vandenberghe (Director-General Climate Action)

4 Oct 2024 · building the EU Hydrogen Economy

Response to Amendment of the free allocation rules in response to the ETS revision/Fit For 55

26 Dec 2023

We would like to thank you for the opportunity to provide feedback to the proposed amendments to Delegated Regulation (EU) 2019/331 on harmonized free allocation of emission allowances Hy 24 manages the worlds largest dedicated clean hydrogen infrastructure fund which is looking to deploy ~2bn EUR of private equity in order to develop and build clean hydrogen infrastructure along the entire value chain, from production to end-use. In order to unlock investments in the Clean Hydrogen space, legislative clarity and certainty are essential to allow Hy24 and its portfolio companies to take final investment decisions as early as possible and to contribute to the realization of the EUs Clean Hydrogen targets. In this context, we welcome the publication and rapid adoption of the proposed amendments to the Free allowance Regulation (FAR), as a means to provide such clarity and help even the playing field between decarbonized hydrogen projects and their conventional counter-parts. In particular: 1. We strongly welcome that the production of (renewable and non-fossil low-carbon) hydrogen via electrolysis is treated in the same way as traditional hydrogen production and entitled to receive free allowances and (where applicable) indirect cost compensation under the same conditions as traditional production methods. This change will encourage the electrification of industrial processes and increase the attractiveness of clean hydrogen production a. In particular, we welcome and support the choice of the Commission the enable this objective by removing the rules on exchangeability of fuel and electricity for the production of electrolytic hydrogen as stated in Preamble 9 2. We would welcome more clarity on the application of free allocation in situations where electrified processes are also eligible to receive compensation for indirect costs in accordance with Article 10a(6) of Directive 2003/87/EC a. We welcome the clarity provided by Recital 9 that Any free allocation granted to indirect emissions of electrified processes should not prejudge the possibility to receive compensation for indirect costs in accordance with Article 10a(6) of Directive 2003/87/EC. However, it is not clear from the body of the Draft Regulation how this objective has been implemented in legislative provisions. We would welcome more clarity on how this objective will be laid out in legislative provisions b. We would also welcome more clarity associated with the statement that financial measures to compensate indirect costs passed on in electricity prices should not compensate the same indirect costs covered by free allocation. i. Although it would be welcome for Hydrogen production to receive both free allocation (FA) as well indirect cost compensation (ICC), we understand that this is not envisioned by the Regulation. We hope that, where the same installation would be eligible to receive both indirect cost compensation as well as free allocation covering inter alia indirect costs, it should have the possibility of choosing which compensation is more appropriate, considering the specificity of its operation and location. ii. Where an installation is not entitled to indirect cost compensation (e.g. because the relevant MS has chosen not to implement such measure) the installation should remain entitled to receive free allocation, in accordance with the applicable horizontal rules. 3. As regards the production of steel, we welcome the consistent approach to reward electrified processes, including the switch from traditional coal-based steel making to Hydrogen direct iron reduction (DRI). a. It is important that a steel plant which uses hydrogen as a feedstock to reduce iron in a DRI furnace should be treated equally, from a free allocation perspective than the traditional based method.The benchmark applicable to DRI steel should have a value at least equal to the sum of the benchmarks applicable to the traditional route
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Meeting with Pablo Fabregas Martinez (Cabinet of Commissioner Adina Vălean) and Bayerische Motoren Werke Aktiengesellschaft and

8 Dec 2023 · AFIR regulation

Meeting with Maroš Šefčovič (Executive Vice-President) and

10 Oct 2023 · Hydrogen