Hydrogen Scotland Renews Its UK Safety Pact With HEA

The Hydrogen Energy Association and Hydrogen Scotland signed an updated memorandum of understanding in Glasgow on 6 October 2026. The pact puts safety, regulation and UK policy at the centre of a partnership that already produced the State of the Hydrogen Nation report.

Scotland is the region businesses rate as the most attractive for hydrogen investment over the next three years. The rules that decide whether that ranking turns into plants still sit with UK-wide bodies, which is the seat this deal is written to occupy.

They Signed the Papers in a Glasgow Hotel

The signing took place at the 18th Hydrogen Scotland Conference in Glasgow, a one-day meeting at the Hilton Glasgow on 1 William Street, running from 08:30 to 19:30. HEA listed the conference as a partner event. The renewed deal extends an existing partnership and sets a shared agenda for the next phase of work, with a particular emphasis on the policy conditions needed to scale hydrogen across the UK.

The stated aim is a stronger collective voice with government and policymakers. That is a lobbying product, not a construction contract. Dr Emma Guthrie, Chief Executive of the Hydrogen Energy Association, put the case in those terms.

Hydrogen deployment does not happen in isolation. It requires collaboration across regions, sectors and the entire value chain. Our partnership with Hydrogen Scotland gives us an important opportunity to combine expertise, identify shared priorities and work constructively on the policy and regulatory environment needed to turn hydrogen ambition into delivery.

Dr Emma Guthrie, Chief Executive, Hydrogen Energy Association

Nigel Holmes, Chief Executive of Hydrogen Scotland, did not issue a separate line on this signing. He did not need to. The two bodies already share a report, a conference series and a memorial award. The new paper names the files they now want to work as one: safety, regulation, and the policy stack that sits behind both.

The Glasgow hall was a suppliers’ room. Valve makers, training-kit firms and project developers filled the floor, which is the constituency a safety-code pact is written for. Public argument about the memorandum itself barely surfaced. Ministers are the audience.

Scotland Tops the Investment Map

The State of the Hydrogen Nation report, published on 27 January 2026, is the evidence base the two bodies already share. It drew on 142 organisations across production, infrastructure, manufacturing, transport, end-use and finance. Respondents put Scotland first for hydrogen investment over the next three years, ahead of North East England and North West England.

The report’s own reasons for that ranking are a supportive Scottish Government policy setting, surplus renewable power that is often curtailed, and a supply chain built on oil, gas and heavy infrastructure. Those are Scottish assets. They do not, on their own, write a UK offtake contract, a national pipeline code, or a Hydrogen Allocation Round award.

HEA launched the findings in Parliament at Portcullis House, with Michael Shanks MP, then Minister for Energy, giving a keynote. Guthrie told that room the sector is ready to deliver and constrained by uncertainty over demand, policy design and timelines. On 8 October 2026, World Hydrogen Day, HEA repeated the jobs warning as the Glasgow ink was drying.

UK HYDROGEN JOBS BY 2030

HEA’s own launch note puts the current path at around 3,800 UK hydrogen jobs by 2030, and the improved path at around 17,000 over the same period. Those figures are survey estimates from the 142 organisations, not a government labour forecast. The gap between them is the argument for a joint policy voice.

The Report They Already Wrote Together

HEA describes the report as its first annual industry health check. Hydrogen Scotland and Hydrogen Ireland helped roll out the survey. That is the collaboration the new memorandum says it is deepening, not starting.

WHAT THE 142 ORGANISATIONS SAID

• Investment plans: 84% expect their UK hydrogen investment to increase over the next 12 months.
• Demand: 51% expect demand for hydrogen products and services to increase over the next year.
• Offtake: 81% of organisations seeking offtakers say agreeing contracts is somewhat or very difficult.
• Government signal: 49% say UK government commitment looks weaker than a year earlier, against 23% who say it looks stronger and 28% who see no change.

Demand, not production kit, is the blocker the report names. Sixty per cent of potential end-users say integrating hydrogen into operations is hard. Among those end-use barriers, 71% cite a lack of suitable infrastructure such as refuelling stations and pipelines, 67% cite high or uncertain supply costs, and 63% cite policy and regulatory uncertainty.

The UK still ranks second only to Germany as a place to put hydrogen money, in the same survey. Respondents also say peer countries, Germany in particular, are moving faster from ambition to execution. HEA’s recommendations include faster delivery of HAR2 and HAR3, an updated hydrogen roadmap, blending into the gas network, and expanding the Hydrogen and Carbon Capture Skills Accelerator pilot to Scotland and Wales.

A joint voice is useful here because the frustration is already shared. Scottish members did not need a new paper to learn that offtake is hard. They needed a channel that reaches the departments that write allocation rounds and demand-side support.

Why the Safety File Still Runs Through London

Scotland is not empty of hydrogen rules. The Scottish Government published hydrogen planning and consenting guidance on 5 February 2026, under the Hydrogen Action Plan of 2022 and a 2045 net-zero target. Planning permission and environmental impact assessment sit with Scottish authorities. That is devolved work, and it is already on paper.

The safety regimes that scare lenders are still Great Britain-wide, or joint. Hazardous Substances Consent is required where two or more tonnes of hydrogen are present on a site. COMAH, the Controls of Major Accident Hazards rules, applies to projects storing more than 5 tonnes of hydrogen, or that amount aggregated with other dangerous substances. In Scotland, COMAH is run by a joint competent authority of the Health and Safety Executive and the Scottish Environment Protection Agency.

THE CONSENTING STACK A PLANT MUST CLEAR

• Planning and EIA: Permission from the relevant Scottish planning authority, with environmental assessment where the 2017 regulations bite.
• Hazardous Substances Consent: Triggered at two or more tonnes of hydrogen on site, decided by the planning authority.
• COMAH: Triggered above 5 tonnes, overseen by HSE with SEPA, with a duty to take all measures necessary to prevent major accidents.
• Environmental authorisation: Industrial emissions and water abstraction moved on 1 November 2025 to the Environmental Authorisations (Scotland) Regulations 2018, administered by SEPA.

HEA’s Planning for Hydrogen Projects working group already treats Scotland, Wales and Northern Ireland as part of the same permission problem as England. Holmes chaired the hydrogen-for-industry session at HEA’s own annual conference on 9 July 2026 at Savoy Place in London. The Glasgow memorandum is the formal version of a relationship that was already running through working groups and podiums.

HSE also closed a review of the Pressure Systems Safety Regulations in late September 2026 and left the rules in place, confirming that hydrogen at 0.5 bar and above is already a relevant fluid. That is another GB file. A Scottish trade body that wants those codes written with developers in mind has to sit with the UK association that already talks to HSE and to Whitehall.

St Fergus to Teesside Is the Physical Pact

The paper version of UK-Scottish alignment now has a steel version in design. National Gas has started engineering design on Project Union’s St Fergus to Teesside leg, a 350-mile hydrogen network from the Aberdeenshire gas terminal to Teesside, inside a planned 1,500-mile underground national hydrogen network. The first phase, Project Union East Coast, is a 300-mile run from Teesside through Yorkshire and the Humber into the East Midlands.

The work is funded as part of a £164 million package for three National Gas projects that would deliver more than 50% of the proposed national network. Early analysis for National Gas puts peak construction employment at around 3,100 jobs and annual direct gross value added at £300 million. Ian Radley, Chief Commercial Officer at National Gas, called the design phase a milestone for Britain’s hydrogen transport infrastructure.

Holmes used that announcement to point at Grangemouth. Low-carbon hydrogen, in his telling, would feed clean fuels, ammonia and sustainable aviation fuel at the site, cut renewable curtailment, and open underground storage for long-duration power. That industrial bet still sits beside an unused £200 million rescue at Grangemouth, which is the other ledger the same cluster is carrying.

Project Union’s hydrogen pipeline from St Fergus in Scotland to Teesside in England will unlock hydrogen’s potential to decarbonise UK industry with production of clean fuels, ammonia, and SAF at Grangemouth from low carbon hydrogen. This UK hydrogen backbone will also reduce renewables curtailment and enable access to large scale underground hydrogen storage sites for the long duration responsive power generation which is essential for UK energy security.

Nigel Holmes, Chief Executive, Hydrogen Scotland, on the Project Union design announcement

HOW THE JOINT CHANNEL WAS BUILT

1. 27 January 2026: HEA publishes the first State of the Hydrogen Nation report, with Hydrogen Scotland and Hydrogen Ireland named as survey partners, and launches it in Parliament.
2. 5 February 2026: Scottish Government issues hydrogen planning and consenting guidance covering planning, Hazardous Substances Consent, COMAH and environmental authorisation.
3. 9 July 2026: HEA holds its annual conference at Savoy Place in London; Holmes chairs the industry session.
4. 6 October 2026: HEA and Hydrogen Scotland sign the updated memorandum at the Glasgow conference, naming safety, regulation and policy as the shared agenda.

Holmes has also been collecting export papers. Hydrogen Scotland signed with Germany’s AquaVentus in September 2025 on North Sea production and transport, and renewed a memorandum with Spain’s Aragon Hydrogen Foundation on 24 March 2026. Those deals face Europe. The HEA paper faces London. Both are consistent with a Scottish industry that wants pipes out and rules in.

One HAR1 Plant Cannot Carry the Ranking

Scotland’s investment ranking is a survey result. The live project list is thinner. Protium’s Cromarty Green Hydrogen Production Facility, a 15 MW plant about 12 km north of Alness beside the Beinn Tharsuinn wind farm, is Scotland’s only scheme with a contract for difference from the UK government’s first Hydrogen Allocation Round. Highland Council granted planning consent in September 2026 after a five-year assessment. Construction is expected in 2027, with operations expected in 2029.

That is one HAR1 plant, still two to three years from making gas, while the report’s improved jobs path assumes faster decisions and bankable demand. Offtake remains the constraint 81% of sellers already named. A joint HEA and Hydrogen Scotland desk cannot sign offtake contracts. It can keep HAR2, blending, storage rounds and safety codes on the same list when those files move through different departments.

HEA, Hydrogen Scotland and Hydrogen Ireland had already announced a shared 2026 conference series after the report, with London in July, Glasgow in October and a Hydrogen Ireland summit in Cork in November. The updated memorandum is the Scottish-UK slice of that alignment, written on the week the UK association was also telling ministers that World Hydrogen Day should be about delivery rather than celebration.

The ranking says Scotland is where investors want to put hydrogen money. The memorandum says the two trade bodies will now argue, together, about the safety codes and policy clocks that decide whether that money becomes a plant, a pipe, or another survey.

Frequently Asked Questions

Who Leads the Hydrogen Energy Association and Hydrogen Scotland?

Dr Emma Guthrie is Chief Executive of HEA. She spent 15 years at Air Products, including as UK Business Development Manager for Hydrogen Energy Systems, and succeeded Celia Greaves, who led the association for two decades. Nigel Holmes is Chief Executive of Hydrogen Scotland. Professor Jon Clipsham is chair of Hydrogen Scotland, with David Hogg of Arup as vice-chair.

What Was Hydrogen Scotland Called Before?

Hydrogen Scotland was formerly the Scottish Hydrogen and Fuel Cell Association, known as SHFCA. It is a company limited by guarantee, registered in Scotland as SC265209, with an office at 14b Johnston Terrace, Edinburgh. HEA is the UK-wide trade body and lists Hydrogen Scotland’s conference as a partner event.

What Hydrogen Tonnage Triggers Extra Safety Consents in Scotland?

Hazardous Substances Consent is required where two or more tonnes of hydrogen are present on a site. COMAH applies above 5 tonnes of hydrogen, or that amount combined with other dangerous substances, and is enforced in Scotland by HSE acting with SEPA. Those two thresholds are separate regimes, not a single permit.

When Was the State of the Hydrogen Nation Report First Published?

HEA dated the first edition 27 January 2026 and presented it as the start of an annual series. The survey covered 142 organisations. Guthrie wrote in the report that it is meant as a practical tool for collaboration between government, regulators and industry rather than a one-off brochure.

What Else Do HEA and Hydrogen Scotland Already Run Together?

Besides the report and the updated memorandum, the two bodies jointly support the Stewart Dow Memorial Award, which honours practical hydrogen and fuel-cell work and is presented around the Scottish conference. That award predates the 6 October signing and is one reason the Glasgow paper reads as a renewal rather than a first handshake.