The Scottish Government’s new Hydrogen Planning and Consenting Guidance Hydrogen: planning and consenting guidance published on 5 February 2026, is a welcome roadmap for all stakeholders navigating the fast-moving world of green and low-carbon hydrogen. Crucially, the Guidance consolidates all regulatory requirements applicable to hydrogen development in a single document, with a view to helping developers and regulators be more aligned from the outset of a project.
The Guidance has been produced against a strong policy framework for growing hydrogen production, namely the Scottish Government’s Hydrogen Policy Statement (2020), Hydrogen Action Plan (2022) and Hydrogen Sector Export Plan (2024) and also through NPF4’s strong support for renewable, low-carbon and zero emissions technologies which includes hydrogen. Hydrogen is considered to be a key component part of the net-zero toolkit ,particularly for energy intensive industries, sustainable fuel production and activities which are challenging to fully electrify such as long-distance transport, low carbon dispatchable power and long duration energy storage.
There is now considerable ambition and active development interest for low-carbon and renewable hydrogen projects: a number of pilot and innovative commercial projects have now been submitted and approved through the planning system across Scotland, such as: Kintore Green Hydrogen Project (Aberdeenshire): a 3GW project, which aims to become the UK's largest green hydrogen development, with an initial 500MW phase planned for 2030; Argyll Hydrogen Hub (Oban): green hydrogen will be produced using the 46MW Carraig Gheal wind farm to power an electrolyser for local transport and industrial use; Whitelee Green Hydrogen Project (Glasgow): a 20MW electrolyser is to be located at Scotland's largest onshore wind farm; Cromarty Hydrogen Project (Highlands): aims to supply hydrogen to local distilleries; Aberdeen Hydrogen Hub (Aberdeen): a facility producing green hydrogen for transport (buses, trucks); and Fife H100 Project (Levenmouth): a world-first project using electrolysis to heat 300 homes with green hydrogen, and other developers are actively engaging with planning authorities and other agencies at pre-application stages.
Scope
As indicated, the key benefit of the Guidance is its comprehensive coverage regarding which consents and licences are required for a hydrogen project, including guidance on the related application and consultation processes. This includes information on planning permission; Section 36 consents; environmental impact assessment (EIA); hazardous substances consent (HSC); compliance with Controls of Major Accidents and Hazards (COMAH); health & safety; environmental permitting and offshore consents (principally marine licences), as well as the relevant thresholds and/or triggers which cause the respective regulatory regimes to be engaged.
Key principles
The need for early engagement and consultation is reiterated throughout the Guidance.
The production of renewable and low-carbon hydrogen remains a new mode of development for which relatively few projects have advanced to consenting and/or licencing stages, hence there is a strong emphasis on pre-application engagement particularly because of the multi-stranded approach required for the various permits.
While many hydrogen technologies are established, the sector’s rapid growth means consenting will often require tailored, cross-discipline thinking on issues from water supply to ecology and community engagement.
Accordingly, it is hoped that engagement will help to de-risk proposals and ensure smooth decision making as increasing numbers of application for hydrogen developments are considered.
Comment
For practitioners, the Guidance takes a pragmatic approach – it encourages non-technical summaries, clear plans and graphics and proportionate reporting. Such good practice is likely to be especially valuable for pilot and scale-up projects co-located with renewables. It also recognises its own limits: the Guidance is deliberately described as a living document intended to evolve as technologies, policy and consenting practice matures. Similarly, while the Guidance includes a reasonably detailed factual account of the various consenting processes that might be relevant, it would benefit from the inclusion of practical examples and/or case studies as practice beds in.
Overall, the Guidance does an important job of reducing fragmentation across consenting regimes and is an invaluable reference for those submitting and determining related consenting applications, but its success will depend on consistent local implementation and continued dialogue between developers, planning authorities and consultees.
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