Electricity is the largest cost item for any electrolyser, and grid fees are a substantial part of the electricity bill. Whether a Power-to-X plant has to pay them is therefore not a technicality but a question of whether it can operate economically. A consultation launched by the Federal Department of the Environment, Transport, Energy and Communications (DETEC) now touches exactly this point. Statements can be submitted until 18 December 2026.

The package

The consultation covers five ordinances in the remit of the Swiss Federal Office of Energy (SFOE): the Energy Efficiency Ordinance, the Energy Promotion Ordinance, the Nuclear Energy Ordinance, the Pipeline Safety Ordinance and the Electricity Supply Ordinance (StromVV). The changes are due to enter into force on 1 July 2027. For Power-to-X, the Electricity Supply Ordinance is the relevant one.

Background: what the law already says

Article 14a of the Electricity Supply Act exempts storage facilities without end consumption from grid fees. Power-to-X plants only get the fees refunded if the electricity is converted back into power, or if they are recognised as pilot and demonstration plants running on renewable electricity. For the latter, the law sets a total cap of 200 MW for the whole of Switzerland, and the rule is limited in time.

What the draft changes

  • The cap is checked earlier: the SFOE is to check whether the 200 MW are already used up during the recognition procedure for a pilot or demonstration plant, not only when the operator later applies to the grid operator for a refund.
  • First come, first served: the date on which the application reaches the SFOE decides. The transitional provision applies this rule to applications that are already pending, and to plants recognised before the change as long as no refund request has been filed.
  • Transparency: the list kept by the SFOE is to include all applications submitted, so that project developers can see how much of the cap is left.
  • Less paperwork: grid operators no longer have to inform the SFOE about refund requests.

In addition, the Pipeline Safety Ordinance is to adopt revised technical rules for gas infrastructure. The published documents do not say whether hydrogen pipelines are specifically addressed; this is worth checking in the statement.

An improvement – within narrow limits

For project developers, the change brings planning certainty earlier: they will know at the recognition stage whether capacity is still available, rather than after the plant has been built. That is a genuine improvement.

The explanatory report, however, states explicitly that the grid fee itself remains untouched and that no new support measures are introduced. The structural problems remain:

  • Power-to-X plants that do not convert back to electricity only benefit as long as they qualify as pilot or demonstration plants, and only within a nationwide cap of 200 MW.
  • The exemption is treated as a subsidy rather than as payment for a service to the electricity system. Project developers therefore often have to choose between the grid fee refund and other support, although they need both.
  • The flexibility that electrolysers provide – absorbing surplus summer electricity, relieving the grid, storing energy across seasons – is not remunerated.

SPIN’s position

In its list of regulatory blockades for Power-to-X, SPIN calls for the grid fee exemption to be classified as a system service that can be combined with other support, and for a full exemption for Power-to-X plants at least until 2050. The full exemption requires an amendment of the law by Parliament. The classification as a system service, however, can be clarified at ordinance level – and this consultation is the place to say so.

A practical consequence for project developers: once the new rule applies, the filing date with the SFOE counts. Anyone planning a pilot or demonstration plant should submit the recognition application early.

Key dates

  • Consultation deadline: 18 December 2026
  • Planned entry into force: 1 July 2027

Sources: SFOE consultation documents, including the explanatory notes on the StromVV revision; Fedlex ongoing consultations.

🤖 AI transparency: This text and its visual were created using AI, reviewed and approved by a human.