On 28 January 2026, the government announced at the 4th Enagás Hydrogen Day the draft bill to create a national hydrogen system and a regulated market in Spain. It is the country's first specific legal framework for this energy vector, and it arrives at a moment of transition: green hydrogen is moving from a phase of announcements and high expectations to a stage of real industrial maturity, in which project viability is measured against far stricter parameters of profitability, real demand and climate usefulness.
Spain has already mobilised more than 3 billion euros in public aid for renewable hydrogen, and the country has accumulated more than 200 announced projects totalling 27,000 MW of electrolysis in the pipeline. But the figure that really defines the moment is a different one: only 11 operating projects, with 33 MW of actual capacity. That enormous gap between what has been announced and what is operating is the obligatory starting point for any serious analysis of the sector.
From a bubble of announcements to a first real wave
The Hydrogen Studies Chair at the Universidad Pontificia Comillas argues in its annual report that the first real deployment wave will arrive between 2026 and 2029, supported by the PERTE ERHA (Spain's strategic programme for renewable energy, renewable hydrogen and storage), European funds and the European Hydrogen Bank auctions. Three elements will explain this shift from promise to reality:
First, the arrival of final investment decisions. Flagship projects such as the bp-Iberdrola alliance in Castellón (25 MW electrolyser), the Valle Andaluz del Hidrógeno (300 MW in Huelva-Cádiz), Basque Hydrogen at the port of Bilbao (10 MW) or Cartagena Large Scale Electrolyzer (100 MW at the Repsol complex) enter construction or commissioning during 2026-2027.
Second, the consolidation of the regulatory framework. The Royal Decree 149/2026, adopted in February, tightens the technical and financial requirements for projects in order to keep out merely speculative initiatives. The transposition of the RED III Directive and the future national law will create a stable, predictable framework, an essential condition for the bankability of these investments.
Third, the emergence of the first demand contracts. Refineries (bp, Repsol, Petronor), the chemical industry, fertilisers (Fertiberia) and steel (ArcelorMittal) are signing the first long-term supply contracts. It is this contracted demand that will finally allow projects to add up financially.
The three challenges that will decide who survives
The Comillas Chair report identifies three challenges that will separate viable projects from those that fall by the wayside:
Insufficient real demand and binding contracts. The sector suffers from an obvious asymmetry: production capacity is available (oversized, even, since European electrolyser factories are running at 10% of their potential), but contracted demand is lacking. Without long-term PPAs equivalent to those in renewable electricity, many projects will not close their business case.
Full transposition of the regulatory framework. Especially of the RED III Directive, which defines the additionality, temporal and geographical correlation criteria that the electricity used to produce «renewable» hydrogen must meet. These criteria are critical for accessing European aid and for marketing the product as such.
Clear price signals for the final product. The gap between the cost of a kilogram of green hydrogen produced (today between 4 and 8 €/kg depending on the project) and the price of the grey hydrogen it would replace (1-2 €/kg) remains wide. Without regulatory mechanisms that internalise the climate cost of grey hydrogen —through mandatory quotas, contracts for difference or an extended CBAM— the equation does not add up.
Implications for developers, industry and public administrations
For energy developers, the message of 2026 is clear: the window of opportunity exists, but it has narrowed. The projects moving forward are those combining a location in territories with a high concentration of renewables and industry (Aragón, Castilla-La Mancha, Andalusia), contracted industrial demand and access to European funding via Hydrogen Bank auctions or IPCEIs. Planning should integrate engineering, environmental permitting, market strategy and the architecture of aid schemes from the outset.
For gas-intensive industries (refining, chemicals, fertilisers, steel, ceramics, glass), green hydrogen has stopped being a future hypothesis and become a real option within 5-7 years. Starting to sign PPAs with local producers now is the strategic equivalent of what happened a decade ago with renewable electricity PPAs: those who move first secure more stable reference prices.
For public administrations, the challenges are twofold: easing administrative permitting (one of the main bottlenecks) and supporting the roll-out of shared infrastructure in hydrogen clusters and valleys, such as the Catalonia Hydrogen Valley or the Basque Hydrogen Corridor.
This new scenario calls for consultancy able to speak three languages at once: that of process engineering (electrolyser design, integration with renewables, ancillary systems), that of environmental and administrative permitting (authorisations, impact statements, grid access), and that of market modelling (PPAs, cost per kilogram, aid mechanisms). The three areas are more intertwined than ever: a decision on siting has implications for the traceability of the renewable electricity used, and that in turn for eligibility for European aid.
At auma auma we support developers, industries and public administrations through this stage of the sector's maturation with an integrated perspective. 2026 marks the point at which green hydrogen stops being a rhetorical promise and starts being a measurable industry. Those who can tell promises apart from bankable projects, and those who design today with the three structural challenges already in mind, will be the ones to write the other half of the story: that of green hydrogen that does work.