The Scottish Government has published new Hydrogen Planning and Consenting Guidance (February 2026), providing long-awaited clarity on how green and blue hydrogen projects should progress through Scotland’s planning and regulatory system.
Importantly, the guidance does not apply to grey hydrogen, which remains unsupported due to unabated emissions.
The guidance confirms that hydrogen is now firmly embedded in Scotland’s planning and energy policy framework, with strong support through the National Planning Framework 4 (NPF4), the Hydrogen Action Plan and national net-zero commitments.
In principle, planning authorities are encouraged to take a positive and proportionate approach to hydrogen development — but only where impacts, risks and safety are clearly addressed.
A central message throughout the guidance is the critical importance of early pre-application engagement.
Developers are strongly encouraged to engage early with planning authorities, Scottish Environment Protection Agency (SEPA), the Health and Safety Executive (HSE) and (where relevant) marine regulators to agree the scope of environmental assessment, safety requirements and consenting routes.
This early coordination is highlighted as key to avoiding delay and duplication later in the process.
The guidance also clarifies that most hydrogen projects will require planning permission, and many will trigger an Environmental Impact Assessment (EIA) depending on scale, location and environmental sensitivity.
There are no fixed EIA thresholds for hydrogen, making early screening and scoping particularly important.
One of the most significant clarifications relates to Hazardous Substances Consent (HSC) and the Control of Major Accident Hazards (COMAH).
Hydrogen is a named hazardous substance, with HSC required from as little as 2 tonnes, and COMAH applying from 5 tonnes. The guidance makes clear that even smaller projects may require consent due to aggregation rules, an area that is often underestimated.
How TNEI Supports Hydrogen Projects
At TNEI, we can support clients throughout the full lifecycle of green and blue hydrogen projects, helping to de-risk planning and consenting from the outset.
We can provide clear advice on the potential implications of this new guidance for your projects and how it may influence consenting strategy and delivery. For example, undertaking early review for your project to flag any key considerations, or if your project is well advanced whether the guidance can reasonably be applied retrospectively.
TNEI supports you through the full project lifecycle including site and feasibility, EIA screening, survey co-ordination, planning application preparation and submission (including EIA where required), post submission support including responding to consultation responses and review/negotiation of planning conditions.
We also provide post consent support including preparation and submission of condition discharge applications and variation applications where required.
