New BSR HyAirport reports published: Legal Framework for hydrogen integration in aviation

The BSRHyAirport partnership has published a set of new reports addressing the legal framework for the use of hydrogen in aviation.

Within the project’s legal framework working group, Eversheds Sutherland was commissioned to analyse regulatory conditions at both European and national level. As a result, three complementary papers have been developed and published:

• Inception Report on the European Union Legal Framework
• National Framework Report
• Executive Summary on the Legal Framework Analysis

Together, these reports provide a comprehensive overview of the current legal landscape and identify key requirements for the future integration of hydrogen in aviation.

Key insights from the reports

Legal frameworks for hydrogen in aviation are still evolving

The analyses show that there is no fully dedicated and harmonised legal framework for hydrogen use in aviation yet. Existing regulations from energy, transport, and safety law apply, but they are not specifically designed for hydrogen-powered aviation.

Strong relevance of EU-level regulation

At European level, a wide range of regulatory areas are relevant, including:

• Energy and hydrogen market regulation
• Aviation safety and certification requirements
• Environmental and climate policies

The reports highlight that EU legislation will play a key role in shaping the future deployment of hydrogen in aviation.

National frameworks differ across countries

The analysis of national regulations shows that legal conditions vary significantly between countries in the Baltic Sea Region. This creates challenges for cross-border implementation and requires alignment efforts.

Gaps and uncertainties remain

The reports identify several regulatory gaps and uncertainties, particularly regarding:

• Handling and storage of hydrogen at airports
• Integration of hydrogen infrastructure into existing airport systems

Addressing these gaps will be essential for enabling large-scale deployment.

Need for coordination across sectors and stakeholders

The legal framework for hydrogen aviation spans multiple sectors. The reports therefore emphasise the importance of close coordination between aviation, energy, and regulatory stakeholders to ensure consistent and efficient implementation.

Legal clarity as a key enabler for hydrogen aviation

Clear and harmonised regulations are identified as a critical enabler for investment and implementation. Establishing predictable legal conditions will support airports, airlines, and industry in planning and deploying hydrogen solutions.

Access all reports here:

Executive Summary on Legal Framework Analysis

EU Legal Framework Report

National Framework Report

Programme Manual Online

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