On 11 August, the Federal Ministry for Economic Affairs and Energy opened the stakeholder consultation on the draft bill amending the WindSeeG in 2026. The deadline for comments closes on 17 August at 10 a.m. Seven days, then, for a law whose effects reach well into the 2040s.
We are asked more often lately why a data company from Konstanz concerns itself with offshore hydrogen. So here are three answers that belong together.
Why we are involved in hydrogen
We do not build electrolysers and we do not lay pipelines. Our work sits one layer below that, at the question of how data from generation, conversion, transport and offtake come together.
Offshore hydrogen is technically demanding, but above all it is a systems problem. A wind farm, an electrolyser, a pipeline and an industrial consumer belong to different companies, fall under different regulations and produce data in different formats. For a functioning system to emerge from that, the data has to be brought together reliably across operator boundaries. Not as a vision, but as operational reality, with availability requirements, documentation duties and auditability.
That is exactly where our contribution lies. It is why we are part of the AquaVentus network, where companies from generation, infrastructure and industry work on implementation. We learn at least as much there as we bring in, and that is a good reason to take part.
Why the WindSeeG matters so much for hydrogen
The draft is titled Act on the Optimisation and Safeguarding of the Expansion of Offshore Wind Energy and contains several points that reset the framework for the coming years.
The expansion target of at least 70 gigawatts by 2045 stands. Annual tenders of between 2,000 and 4,800 megawatts are envisaged. For the first time, two-sided contracts for difference (CfD) are to be available as a hedging instrument, though in a two-stage model in which the CfD only applies if no company can be found to develop the site without support. The regular operating life of new wind farms is to rise from 25 to 35 years. And provisions for cross-border cooperation projects are to be created.
For hydrogen, a different point is central: the draft aims to enable combined electricity and hydrogen infrastructure and to anchor integrated planning in the site development plan. That sounds technical, but it decides whether electrolysis, hydrogen transport and the power grid can be planned together or continue to be planned one after the other. On the SEN-1 pilot site in the North Sea, wind energy is to be brought ashore primarily as hydrogen. Whether that becomes a viable path depends on what the law explicitly permits.
Then there is the timeline. The 2026 offshore tender has been suspended and postponed to 2027. At AquaDuctus, the first planned hydrogen pipeline in the German North Sea, geotechnical surveys have been running off Norderney since July. Construction start no earlier than 2028, commissioning of the first phase in the early 2030s, full build-out targeted for 2035. What ends up in the legal text in these weeks therefore affects assets meant to transport hydrogen ten years from now.
Why hydrogen has to be thought of in European terms
The North Sea is a single connected space; the regulation is not. A pipeline does not end at the boundary of the exclusive economic zone, but a rulebook does.
The draft takes this up in two places: cross-border cooperation projects and the option of hydrogen transit lines. Both amount to acknowledging a plain fact. Germany, the Netherlands, Denmark, Norway and the United Kingdom are all planning around the same molecules, but each under its own law, with its own permitting logic and its own certification requirements for green hydrogen.
From our perspective, this becomes very concrete. If a molecule is produced on German territory, transported through a line with Dutch participation and consumed in Belgium, then guarantees of origin, measured values and balancing data have to fit together across system boundaries. Not approximately, but in a form that withstands an audit. Where definitions diverge, the result is not technical problems but transaction costs. And the market pays those in the end.
In closing
That is why I think it is right to read the WindSeeG amendment as more than a German expansion question. It is also a contribution to how well the German framework connects to its European environment. Comments are due in final form on 17 August 2026. I am curious how the industry assesses the draft and how the further parliamentary process develops.
Glossary: offshore wind and hydrogen
WindSeeG
The Offshore Wind Energy Act of 13 October 2016 governs site planning, preliminary surveys, tendering and grid connection for offshore wind farms in the German exclusive economic zone and territorial sea. It also sets the expansion targets, currently at least 70 gigawatts by 2045.
On 11 August 2026, the Federal Ministry for Economic Affairs and Energy submitted the draft amendment for stakeholder consultation. Among other things, the draft provides for annual tenders of between 2,000 and 4,800 megawatts, two-sided contracts for difference and an extension of the standard operating life from 25 to 35 years.
Often confused with: the EEG, which governs support for onshore wind and photovoltaics, and the NABEG, which concerns onshore transmission grid expansion.
Legal basis: WindSeeG, Federal Law Gazette I 2016 p. 2310
Site development plan (FEP)
The FEP is drawn up by the Federal Maritime and Hydrographic Agency and determines which sites are tendered in which year at which capacity, how they are connected to the grid, and in what sequence this happens. It is therefore the link between marine spatial planning and the concrete tenders run by the Federal Network Agency.
The FEP 2025 currently applies. A stated goal of the ongoing reform debate is to merge the planning of electricity and hydrogen infrastructure in the FEP 2026.
Often confused with: the spatial plan for the EEZ. The spatial plan sets out which uses are permissible in principle and where. Within that framework, the FEP specifies the sites and the schedule for energy generation.
Responsible authority: BSH
Exclusive economic zone (EEZ)
The maritime area seaward of the territorial sea, which ends at 12 nautical miles, out to a maximum of 200 nautical miles from the baseline. The EEZ is not state territory. The coastal state holds sovereign rights there to explore and use natural resources, including energy generation, but not full territorial sovereignty.
For offshore projects this has practical consequences: general construction law does not apply but a dedicated permitting regime does, and other states may, under certain conditions, lay cables and pipelines through the EEZ. For cross-border hydrogen lines, that is precisely the relevant point.
Often confused with: the territorial sea and territorial waters. Both lie landward of the EEZ and are state territory.
Legal basis: UN Convention on the Law of the Sea, Art. 55 ff. and Art. 79
Offshore grid connection system (ONAS)
The link between an offshore wind farm and the onshore transmission grid, consisting of a converter platform, subsea cable and land cable up to the grid connection point. It is built and operated not by the wind farm operator but by the responsible transmission system operator. The costs are recovered through grid fees.
The state of grid connection build-out is the limiting factor for the expansion path. A wind farm without an assigned and scheduled connection system cannot be realised, however attractive the site may be.
Often confused with: the array cabling between the turbines inside the farm, which belongs to the wind farm and is the operator's responsibility.
Offshore electrolysis
The production of hydrogen at sea, either on a dedicated platform or directly at the turbine. The hydrogen is transported ashore by pipeline rather than as electricity via subsea cable.
The economic core of the concept lies in transport: for the same corridor width, a pipeline can carry considerably more energy than a subsea cable, and it is usually cheaper to build. The open questions are mainly water treatment, maintenance under offshore conditions and scaling to industrial capacities.
Often confused with: onshore electrolysis fed with offshore wind power. That is a different plant and regulatory case, even if the result is the same molecule.