WindSeeG Amendment 2026
What the draft law provides for offshore hydrogen – and what we are calling for in the parliamentary process.
What it is about
The Offshore Wind Energy Act (WindSeeG) governs where, when and under what conditions wind farms are built in the North Sea and Baltic Sea. The cabinet draft aims to put expansion on a stable footing after the 2025 auctions, which for the first time received no bids, and to reduce the burden on electricity and grid customers.
For offshore hydrogen the amendment is a turning point: for the first time, installations in other energy generation areas may be connected to the electricity grid, and electrolysers are expressly named as an intended use. The draft thus implements the coalition agreement's mandate to enable hybrid connections for electricity and hydrogen.
What the draft provides
Section 3 no. 9
The restriction to installations “that are in each case not connected to the grid” is deleted. “In particular electrolysers” are named. According to the explanatory memorandum, this allows both feeding into the electricity grid and using electricity from the onshore grid.
Section 3 no. 3a and no. 8
The electrolyser receives its own statutory definition, and hydrogen is expressly named as a purpose of other energy generation installations.
Section 4(3), section 5(2a)
Testing is no longer limited to concepts without a grid connection. The site development plan may designate electricity connection cables for other energy generation areas.
Section 69(7)
The planning approval for electrolysers is limited to 35 years, as for wind turbines.
Explanatory memorandum
Other energy generation areas currently exist only in the form of SEN-1. Testing at industrial scale is to take place there.
What the text of the law does not provide
- A right to a grid connection and to an allocation of grid connection capacity for other energy generation areas. Section 55 grants it only to awarded sites.
- Hydrogen pipelines: the text of the law contains no provision on them. The hybrid connection appears only in the explanatory memorandum.
- The inclusion of offshore electrolysis in the Grid Development Plan.
- Unconditional testing on SEN-1: according to the explanatory memorandum, it is to take place “insofar as” the expansion targets for grid-based generation on sites are secured.
Our positions
AquaVentus welcomes that the draft opens up offshore sector coupling for the first time. For the opening to work in practice, four narrowly defined building blocks are missing. This is not about a debate of principle and not about departing from the 70 GW pathway.
- 1
Relax the pilot limit for electrolysis
On regular sites, the draft permits electrolysers only as pilot installations, up to 2.5 percent of the allocated grid connection capacity. With the connections of 300 to 400 megawatts that have been usual so far, this is 7.5 to 10 megawatts; for a 2 gigawatt site it is 50 megawatts. That is a demonstrator, not testing at industrial scale: platform, topside and hydrogen export are fixed costs that do not pay back at this size, and the effect on cable utilisation cannot be measured. In addition there is the pilot status: only the first three installations of a type are permitted.
We call for the rigid limit to be deleted. If a limit is to remain, it belongs site by site in the site development plan, where the BSH has the lead. For SEN-1 we consider at least 250 megawatts necessary.
Section 69(3) sentence 3 no. 3, section 3 no. 8a WindSeeG-E
- 2
Credit wind energy in other areas towards the 70 GW target
The expansion target remains untouched. Grid-connected wind turbines in other energy generation areas should be credited towards it. The explanatory memorandum makes industrial testing subject to the expansion targets for grid-based generation on sites being secured. Crediting removes this conflict of objectives, including for the BSH in site planning.
Section 1(2) WindSeeG
- 3
Connection obligation for transmission system operators
The draft permits the grid connection but does not establish a right to it – neither to connection nor to an allocation of capacity. For awarded sites, section 55 regulates both; for other energy generation areas it is missing. Without this right, no project can be financed.
Section 3 no. 6 and no. 14 WindSeeG, section 17d EnWG
- 4
A uniform permitting regime for hydrogen pipelines
Pipelines such as AquaDuctus connect an area and at the same time transport hydrogen across borders. Including their transit sections in the German EEZ, they should fall uniformly under the WindSeeG instead of being caught in parallel procedures.
Addition to the WindSeeG
What grid planning must do now
The cabinet draft of 2 September 2026 creates the legal basis for the grid connection of other energy generation areas (section 3 no. 9, section 4(3), section 5(2a) WindSeeG-E). Grid planning with a lead time of around seven years cannot wait for the law to enter into force. In the scenario framework, the Federal Network Agency also anticipates other future legal changes, for example the crediting of capacity from neighbouring economic zones.
In the consultation on the Gas and Hydrogen Scenario Framework, AquaVentus therefore calls for the SEN-X entry to be marked “yes” in the joint scenario. SEN-X is the total potential of 10 gigawatts of offshore wind capacity in zones 4 and 5; it is the only expansion stage on the joint electrolyser list with the status “design planning” or better that is not marked for the joint scenario.
What is at stake
EUR 1.7 bn
per year
Lower net infrastructure costs of offshore integration through offshore sector coupling in the 70 GW scenario. In the 55 GW scenario the figure is around EUR 0.5 bn.
Source: Frontier Economics, commissioned by AquaVentus, November 2025
52 → 65 %
Subsea cable utilisation
Utilisation of the offshore power transmission infrastructure in the 70 GW scenario when either electricity or hydrogen can be transported away.
Source: Frontier Economics, commissioned by AquaVentus, November 2025
EUR 5 to 10 bn
per connection line
Investment for one offshore connection line. The costs are passed on to electricity customers via the offshore grid levy.
Source: Explanatory memorandum to the draft law, cabinet version
Questions and answers
Is opening up SEN-1 not enough?
It is an understandable first step, but it does not yet carry a project. The text of the law permits the grid connection of other energy generation areas but gives no right to it, and according to the explanatory memorandum testing is subject to the expansion targets for electricity being secured. Permitting is not the same as carrying.
Does hydrogen at sea come at the expense of electricity grid expansion?
No. The 70 GW target remains, and we call for grid-connected installations in other areas to be credited towards it. Those who can transport either electricity or hydrogen make better use of the expensive subsea cables: according to Frontier Economics from 52 to 65 percent in the 70 GW scenario. At the same time, nobody is forced to use this option; the opening creates an option, not an obligation.
Who pays for the infrastructure?
According to the explanatory memorandum to the draft law, offshore connection lines require investments of around EUR 5 to 10 billion each. They are passed on to electricity customers via the offshore grid levy. Every line that is replaced or relieved by a hydrogen pipeline reduces this burden.
All documents in one place
AquaVentus positions
Statement
Statement on the WindSeeG amendment
Our assessment of the ministerial draft with specific proposals for additions.
17 August 2026
Press release
AquaVentus welcomes WindSeeG amendment and calls for more courage
The press release on the ministerial draft.
17 August 2026
Statement
Electricity Scenario Framework 2027-2040/2045
Why SEN-1 is relevant for power system modelling and combined concepts must be considered within the 70 GW target.
28 September 2026
Statement
Gas and Hydrogen Scenario Framework 2027-2040/2045
Why SEN-X must be taken into account in the joint scenario.
28 September 2026
Policy paper
Combined connection concepts
Why cable and pipeline together are the most economical way to connect far-offshore areas.
January 2025
Studies
Study · Frontier Economics
Reducing system costs through offshore sector coupling
Up to EUR 1.7 billion lower system costs per year.
November 2025
Study · E-Bridge Consulting
Combined transport systems reduce expansion costs
Up to EUR 31 billion in savings (net present value) through combined connection concepts.
September 2024
For press and politics
Talks for members of parliament and policy advisers
We are happy to present the results of the studies in person and to explain our proposals on the text of the law.
verein@aquaventus.org