Scotland’s transition to net zero will reshape the workforce and the skills needed across the transport and construction sectors.

This report looks at how these changes could unfold between 2026 and 2045. It focuses on activities that will help reduce emissions, including renewable energy, improving the energy efficiency of existing buildings, and the move to electric vehicles.

Route maps for the construction sector and transport sector illustrate the expected workforce and skills needs at different stages of the transition.

Key findings

• Transport employment: Employment in vehicle and equipment repair and maintenance is expected to decline slightly by 2045. The additional employment needs associated with net-zero grows from around 200 jobs in 2026 to 2,800 additional jobs by 2045. This reflects the projected growth in Scotland’s electric car fleet, from around 122,000 in 2025 to nearly 3 million by 2045.
• Construction employment: Overall construction employment is expected to grow modestly. Additional employment needs associated with net zero rises from 2,000 jobs in 2026 to around 13,800 additional jobs by 2035. The rollout of technologies such as air source heat pumps will increase demand for workers in renewable energy installation and building retrofit, with installations projected to rise from around 7,000 in 2025 to 1.7 million by 2045. Training will also need to expand to meet demand for specialist construction skills.
• Emerging skills: New technical skills will be needed as electric, renewable energy and digital technologies become more widely used. Workers will also need to adapt their existing skills, with reskilling helping those with petrol and diesel engine expertise move into EV-related roles.
• Moving between sectors: Many technical and practical skills are transferable between transport, construction and other sectors, creating opportunities for workers to move between industries as demand changes. However, sector-specific qualifications and experience may limit how quickly they can transition, making accessible training and clear routes into new roles important.
• Geographical variation: Net zero-related employment in transport and construction is likely to remain concentrated in Scotland’s main urban and industrial regions, including Glasgow, Edinburgh and Aberdeen. These areas already have a large share of the workforce needed to support the transition.

The report concludes that coordinated workforce planning across sectors will be needed to ensure Scotland has the skills required for the net zero transition. Policy priorities include expanding training, supporting upskilling and reskilling, keeping training aligned with new technologies, and making it easier for workers to move between sectors.

If you require the report in an alternative format, such as a Word document, please contact info@climatexchange.org.uk or 0131 651 4783.

Page cover photo by Jeriden Villegas on Unsplash.

Research completed: July 2026

DOI: https://doi.org/10.7488/era/7189

Executive summary

Scotland’s transition to net zero will change the number and types of workers and skills needed in the transport and construction sectors. This report assesses workforce and skills requirements in each sector from 2026 to 2045. It focuses on key activities expected to play a major role in reducing emissions, including renewable energy systems, retrofit programmes to improve the energy efficiency of existing buildings, and the shift to electric transport. The results are presented through sector‑specific route maps for construction and transport, outlining how workforce demand and skills needs develop over time.

Findings

Transport employment

Employment in vehicle and equipment repair and maintenance is projected to decline slightly over the long term, to 2045. However, the expansion of associated technologies is expected to increase demand for new technical skills. Employment linked to electrical vehicle (EV) related activities is projected to increase from around 200 jobs in 2026 to approximately 2,800 jobs by 2045.

The transition is likely to happen mainly by adapting existing jobs. Workers will need skills related to electric and digitally enabled vehicle systems, including electrical systems, battery technologies, and digital tools used to identify and diagnose vehicle problems. Reskilling, which means learning new skills for a different type of work, will also help workers who currently specialise in petrol and diesel engine technologies to move into EV-related activities. The number of electric cars in Scotland is projected to increase from around 122,000 in 2025 to nearly 3 million by 2045.

Construction employment

Overall employment in construction is projected to grow modestly. Activities linked to the net zero transition are expected to grow more rapidly during the early rollout of low‑carbon technologies. For context, the total number of installed air source heat pumps is projected to increase from around 7,000 units in 2025 to approximately 1.7 million by 2045.

Employment linked to net zero construction activities is projected to increase from 2,000 jobs in 2026 to around 13,800 jobs by 2035, before declining from 2039 onwards. A growing share of the workforce will need to adapt existing skills to support renewable energy installation and retrofit. This will require both upskilling – developing new skills within an existing job – and expanding training provision to avoid shortages of workers with specialist construction skills.

Emerging skills

Across both sectors, new skills will be needed as electric technologies, renewable energy systems and digital technologies become more widely used. In transport, these include skills related to EV systems, digital tools for identifying and diagnosing vehicle problems, and connected vehicle technologies. In construction, emerging skills are associated with solar energy systems, smart energy infrastructure, systems to manager energy use in buildings, and technologies and solutions to improve energy efficiency.

Cross-sector workforce mobility

There is significant overlap between the technical skills used in transport and construction, particularly for roles such as electricians, engineering technicians, and telecommunications installers. There is also substantial overlap between skills used in these sectors and in other parts of the economy, especially manufacturing and professional services. This suggests that many core technical and practical skills are transferable between sectors.

For transport-related activities, the greatest overlap with other sectors is in technical skills. For example, 80% of transport sector skills associated with designing and creating are also used in manufacturing and professional services, while 72% of transport sector skills related to operating and monitoring are also used in manufacturing.

For construction, around half of skills are shared with the manufacturing sector. More than half of construction skills in some areas are also shared with professional and technical activities, particularly skills related to higher-level analysis and design.

This overlap creates opportunities for workers to move between sectors as demand changes. However, sector-specific qualifications, certification requirements and experience may affect how quickly workers can transition. Accessible training and clear routes into new roles will therefore be important to support workforce mobility.

Geographical variation

Regional analysis shows that employment in both the construction and transport sectors is concentrated in a small number of urban and industrial regions. This includes major city regions such as Glasgow, Edinburgh and Aberdeen. These areas currently have a large share of the relevant workforce and are likely to remain key hubs for net zero-related activities.

Conclusions

Coordinated, cross-sector workforce planning is critical to ensure there are enough workers with the correct skills to meet the scale and pace of the transition. Our analysis suggests the following policy priorities:

• Expand training in key technical occupations, including electricians, engineering technicians, construction trades and vehicle technicians, to meet future demand.
• Prioritise upskilling and reskilling programmes so that workers can adapt their existing skills to new technologies.
• Ensure training keeps pace with the transition by incorporating renewable energy systems, electrification infrastructure and digital technologies.
• Strengthen collaboration between industry, training providers and government so that training reflects technological developments and changing workforce needs.
• Policies that support workers to move between sectors and develop skills that can be used in different types of work could help address emerging labour shortages.

Glossary and abbreviations

Introduction and purpose

Scotland’s legally binding 2045 net zero target is driving major transformation across the economy. This shift is particularly important in the construction and transport sectors, which underpin decarbonisation efforts. Achieving this transformation requires a skilled and adaptable workforce. Existing evidence shows that policymakers and industry lack a clear understanding of how workforce and skills needs will evolve, where shortages will emerge, and which interventions will prove most effective (Climate Change Monitoring Report 2024, Chapter 3: Transport; Built Environment and Construction Factsheet). These challenges affect construction most acutely, where the sector already faces an annual shortfall of more than 5,000 workers (CITB, 2025). Transport also faces significant pressures in the transition to net zero, as it remains Scotland’s highest-emitting sector. Forthcoming policies, such as the Vehicle Emissions Trading Scheme and potential changes to the HGV CO₂ emissions regulatory framework, will directly shape workforce demand and training needs (Department for Transport, 2026; Energy and Climate Change Directorate, 2025).

In response, we address these evidence gaps through a detailed assessment of future workforce and skills needs to 2045. We apply a consistent, quantitative skills-mapping framework across the construction and transport sectors. This framework builds on existing analysis, including the Construction Sectoral Skills Assessment 2024, the Climate Emergency Skills Action Plan 2020–2025 (CESAP), and the associated CESAP pathfinder reports (WP1, WP2).

We provide robust, forward-looking evidence to support Scotland’s transition to net zero by examining future workforce demand in these sectors. In particular, this focuses on identifying skills needs, addressing recruitment and retention challenges, and analysing the factors that drive industry investment in workforce development. We present a detailed picture of the workforce required to meet net zero ambitions. This includes needs in energy supply, domestic retrofit, and electric vehicles (including charging points).

For this work, we define ‘net zero’ according to the assumptions and aims set out in the Climate Change Committee’s Balanced Pathway. While different net zero pathways may lead to slightly different outcomes, the broad direction of the results in this study still reflects the scale and scope of the skills landscape across a number of net zero scenarios.

This work builds on existing evidence, which presents the pipeline of various activities needed to achieve Scotland’s net zero target by 2045. In particular, we translate the target pipeline in energy generation, domestic retrofit and EV take-up to employment demand by occupation, and perhaps more informatively, by skills. We forecast workforce demand to 2045, highlight sectoral and cross‑sectoral skills gaps and training needs, and map geographic and temporal variations in workforce requirements across Scotland. By examining employment demand on a skills basis, our work provides government, industry and workers with a clearer picture of the skills, jobs and training requirements needed to enable Scotland’s transition to net zero, a better understanding of the opportunities it presents, and the risks and barriers involved.

Approach

Overview

This section sets out the key assumptions and analytical approach used to interpret net zero scenarios and pathways across the report.

Preparing a net zero technology pipeline

Our approach followed a three-step process for the construction and transport sectors,^[1] moving from broad technology analysis to detailed occupational and skills implications. The first stage involved technology mapping, identifying emerging and relevant technologies likely to influence construction and transport under net zero pathways. We then linked these technologies to sectors across installation, operation, and maintenance phases to assess their impact on workforce demand. Finally, we mapped these sectors to occupations using the Standard Occupational Classification (SOC) and occupational shares derived from the Labour Force Survey (LFS), before linking occupations to skills using Skills England’s UK Standard Skills Classification (SSC).

Technologies provide a useful starting point for analysing skills requirements because their deployment shapes the activities that need to be carried out across sectors (Cirillo et al., 2023). Each technology requires specific infrastructure, installation processes, operational systems, and maintenance activities, all relying on particular occupations and skills. Focusing on technologies, therefore, allowed us to link the scale and timing of technology deployment to the workforce capabilities needed for net zero delivery. This process allowed us to quantify skills needs, identify bottlenecks, and highlight training priorities with enough detail to inform planning and policy.

As agreed with the Scottish Government, we used the Climate Change Committee’s (CCC) ‘Balanced Pathway’ scenario from the latest Carbon Budget for Scotland, which outlines a pathway to net zero emissions in Scotland by 2045. Within this framework, we identified key technologies expected to affect construction and transport under net zero pathways, including energy systems, domestic retrofit, and electric vehicles with charging infrastructure. These technologies were selected for their expected emissions-reduction impact and their potential to reshape workforce demand across sectors.

Table 1 outlines the scale and deployment pipeline of key net zero technologies across energy, domestic retrofit, and electric vehicles (including charging points). These projections indicate the potential demand for construction, installation, and vehicle maintenance activities associated with the net zero transition.

Table 1: Pipeline. Sources: Economic Impact Scenarios for Scotland’s Energy Transition; Appendix B – Capacity Projections Strong Ambition; Climate Change Committee (CCC) carbon budget methodology; Technology definition aligned to CITB (Domestic Retrofit Workforce Analysis 2025-2050); CCC-Cambridge Economics – Scotland EV data; CCC Scotland’s Carbon Budgets Report

In the energy sector, there is expected to be a substantial expansion in renewable generation capacity, driven primarily by wind. Total wind capacity is projected to increase from 14.7 GW in 2025 to 58.1 GW by 2045. Offshore wind is expected to account for an increasing share of this growth, increasing from 3.2 GW to 32.2 GW over this period. Onshore wind is also expected to increase, although at a slower pace, reaching 25.9 GW by 2045. Solar photovoltaic (PV) capacity is expected to increase steadily from 1.1 GW to 6.2 GW, while grid storage (including batteries) is expected to expand from 1.9 GW to 5.7 GW. Hydrogen deployment is expected to initially be limited, before accelerating from 2035 onwards, reaching 4.2 GW by 2045. Hydro capacity is expected to remain broadly stable.

In the domestic retrofit sector, the pipeline is characterised by a rapid scale-up of low‑carbon heating systems and energy efficiency measures. Air source heat pump deployment is expected to increase considerably, from 7,000 units in 2025 to over 1.7 million by 2045. Electric heating is also expected to expand, reaching 377,000 installations by 2045. The heat network is expected to grow from negligible levels to over 234,000 connections, while communal heating conversion is expected to increase more moderately. Insulation measures, including hot water tank insulation and loft insulation, are expected to be deployed at scale in the earlier years before stabilising.

For electric vehicle activities, the transition is reflected in the rapid growth of the vehicle fleet and supporting infrastructure. Electric cars are expected to account for the largest share, increasing from 122,000 in 2025 to nearly 3 million by 2045. Electric vans and motorcycles are also expected to increase substantially, reaching over 428,000 units by 2045. Heavy goods vehicles and rigid vehicles are expected to increase to over 35,000 units, and electric buses are expected to increase to almost 10,000 units by 2045. A substantial rollout of charging infrastructure is expected, with charge points increasing from 5,600 to 52,000 in 2045. This expected sustained growth implies an ongoing expected demand for installation, maintenance, and electrical infrastructure across the period.

Additionally, we estimated expected peatland restoration activity using national targets and projections from the CCC’s Balanced Pathway. The CCC’s projections indicate a substantial expected increase in restoration, reaching 150,000 hectares of peatland restored or rewetted by 2045. This increase is equivalent to an average annual restoration rate of approximately 12,750 hectares. These estimates inform the assessment of workforce requirements associated with peatland restoration.

This pipeline indicates that the net zero transition will require substantial investment in construction and installation activities, particularly in the short to medium term, followed by increasing demand for operation and maintenance roles. The scale and timing of deployment across energy, domestic retrofit, and transport provide a key input for assessing future workforce and skills requirements (see Sections 5.2 and 6.2).

Sector linking

This section describes the methodology used to translate the investment and delivery pipeline into sector-level workforce requirements.

Sector definition and scope

The pipeline presented in Table 1 provides projections of technology deployment across energy, domestic retrofit, and electric vehicles. To assess the workforce implications of the pipeline, it is necessary to map the associated activities to economic sectors. This is achieved using the Standard Industrial Classification (SIC) framework, which enables alignment with national accounts and labour market data.

The majority of activities associated with the energy and domestic retrofit and peatlands pipeline are mapped to construction (Section F, according to the SIC classification). This is because the delivery of the pipeline is predominantly driven by construction and installation activities, particularly during the build-out phase. The deployment of renewable energy infrastructure requires substantial civil engineering works, including site preparation, foundations, structural assembly, and grid connection. All of these are classed as construction‑related activities. Similarly, domestic retrofit measures, such as the installation of low-carbon heating systems, insulation, and heat networks, are implemented at the building level and rely heavily on construction trades, including electricians, plumbers, and general construction operatives.

In contrast, the electric vehicle (EV) pipeline spans multiple sectors. The maintenance and repair of EVs are mapped to maintenance and repair of motor vehicles (SIC G45), reflecting ongoing servicing and operational requirements. The installation of EV charging infrastructure is mapped to repair and installation of machinery and equipment (SIC C33), capturing the technical and electrical work associated with charging systems. For the purposes of this report, we refer to this group as transport-related activities (vehicle and equipment repair and maintenance).

Converting technology deployment into employment demand

Table 2 summarises the key assumptions and data sources used to convert technology deployment into employment estimates across the energy, domestic retrofit, and electric vehicle technologies. The conversion approach varies by technology type, reflecting differences in how deployment translates into labour demand.

Table 2: Employment conversion assumptions and sources. Note: Assumptions are derived from literature and industry reports and reflect typical operating conditions. Where possible, values have been triangulated across multiple sources.

For energy technologies, employment is estimated using job-years per gigawatt (GW) of installed capacity. This is based on the literature on the employment impacts of the energy transition. The coefficients used capture the labour requirements associated with the construction, installation, and operation of energy infrastructure. The employment factors vary across technologies, reflecting differences in labour intensity. Higher values are observed for technologies such as hydro and hydrogen, and lower values for grid storage.

In the domestic retrofit sector, employment is derived using a deployment-per-worker ratio. These ratios link the number of installations to the workforce required to deliver them. The ratios are based on industry evidence and scenario analysis. They reflect the labour requirements associated with installing different retrofit measures, such as heat pumps, insulation, and heat networks. The variation across technologies reflects differences in installation complexity. Labour-intensive measures, such as ground source heat pumps, require greater input from workers per unit of deployment than other interventions, such as insulation.

For electric vehicles, there is a limited availability of standardised data on labour requirements. As such, we draw on industry experience and operational evidence to estimate workforce needs. A bottom-up approach is adopted, using assumptions on inspection frequency, repair rates, and the time required for maintenance and repair. These assumptions are informed by a combination of regulatory guidance, industry standards, and empirical studies. They reflect the ongoing operational nature of labour demand in the transport sector, which is driven by fleet size and utilisation rather than one-off installation activities^[4]. For electric vehicle charging infrastructure, employment is estimated using an employment coefficient (jobs per £1 million of output) derived from manufacturing productivity data. This captures the labour required to install and maintain charging infrastructure, linking investment levels to workforce demand.

Finally, for peatland restoration, employment is estimated using a labour intensity expressed in full-time equivalent (FTE) employment per hectare. This is based on available evidence from workforce and economic impact studies. A proportion of this employment is mapped to construction-related activities, reflecting the role of site preparation and restoration works.

Employment estimates are derived by applying the coefficients presented in Table 2 to the technology deployment projections outlined in Table 1. This approach provides a consistent framework for translating projected levels of deployment into workforce requirements across different technologies. The application of these coefficients to the projected deployment pathways produces estimates of employment demand over time. These projections capture the scale and timing of workforce requirements associated with the transition to net zero at sectoral level.

Occupation and skills linking

The sector-level workforce projections, presented in terms of the Standard Industrial Classification (SIC), provide the foundation for estimating occupational and skills demand. Sector employment requirements are mapped to occupations using the UK Standard Occupational Classification (SOC), which classifies jobs by tasks and required skills (see Appendices). The use of SOC ensures consistency with national employment data and enables robust comparison across sectors, geographies, and scenarios.

Occupational employment shares by sector are derived from Labour Force Survey (LFS) data for Scotland over the past five years (2021-2025). Using multiple years reduces short‑term fluctuations and sampling variability, especially for smaller sectors and occupations. This approach provides more stable estimates of each sector’s occupational structure, which we use to allocate projected employment. The occupational structure captures core delivery sectors (such as civil engineering and construction), as well as supporting sectors involved in installation, maintenance, and related professional services.

We then link SOC-based occupational employment to skills requirements using the UK Standard Skills Classification (SSC)^[5], a newly developed skills taxonomy released by Skills England (see Appendices). The SSC provides a comprehensive and structured list of skills required by each occupation, allowing occupational projections to be translated into detailed estimates of skills demand. It is structured as a hierarchical framework covering 3,343 individual skills, organised into “skill groups”. These in turn are structured by “skill areas”, linked to 22 high level “skill domains” (see appendix B for more detail). The linkage between SOC and the SSC enables a systematic mapping from sectoral workforce requirements to occupation-specific and skill‑specific needs. Moreover, the SSC is explicitly tailored to the UK labour market context, reflecting UK occupational structures. It incorporates up-to-date information on employer skill demand, including emerging skills such as installing EV charging points, maintaining electrical charging systems, and installing vehicle batteries. This methodology supports a more accurate and policy-relevant assessment of current and future skills needs, particularly in the context of net zero transitions and workforce planning.

We rank skills using a relevance index that combines projected employment levels with information from the UK SSC. The first step links projected employment to occupations, which the SSC then maps to associated skills. This mapping allows us to estimate how many workers are likely to use each skill, based on projected employment by occupation. This component of the index captures the scale of labour demand associated with each skill.

The index also incorporates the frequency with which each skill appears across occupations in the SSC. We count the number of occupations linked to each skill and use this as an additional weighting factor. Skills associated with a larger number of occupations receive higher scores, reflecting their broader relevance across the workforce. This step prevents the index from relying only on employment levels within individual occupations. Instead, the index accounts for how widely a skill is used across different roles.

The relevance index reflects both the scale of employment associated with a skill and the breadth of its use across occupations. This approach highlights both specialised skills linked to high-employment occupations and cross-cutting skills required across a wide range of occupations in the labour market.

Regional analysis

While the main analysis focuses on the net zero transition at the Scotland-level, regional analysis is also provided to support regional planning and policy development. This indicates the occupations needed across regions, while recognising limitations in the granularity and quality of pipeline data at this level.

For the regional analysis, the technology pipeline is disaggregated by council, and the Scotland-level employment estimation framework is applied consistently across council areas. This approach includes the use of employment intensity assumptions and sector‑specific conversion factors to translate technology activity into workforce requirements. Table 3 summarises the sources and methods used.

Table 3: Sectors and council authority allocation methods. Notes: Regional data were not available for grid storage (including batteries) and peatland restoration at the time this document was completed. As these activities account for a small share of total construction employment (less than 1% and 1.6%, respectively), their exclusion from detailed local allocation is not expected to considerably affect overall regional patterns.

For energy technologies, we allocate activity based on historic (2014–2024) Scottish council‑area shares of installed capacity (MW). These historic shares are used to approximate both the relative scale and the pace of technology deployment across regions. To do this, we make the assumption that past spatial patterns provide a reasonable indication of future geographic distribution.

For hydrogen, where consistent historical data are unavailable, we use Hydrogen Scotland’s map of active and planned projects. Areas with a higher concentration of existing or planned hydrogen projects are assumed to have relatively greater employment impacts.

As showed in Section 4.3, domestic retrofit is the largest driver of employment impacts within construction. To allocate retrofit-related activity locally, we use population projections for 2025–2045 to approximate the future distribution of housing-related interventions. The distribution of retrofit activity is closely linked to housing stock, and so population distribution. More densely populated areas, therefore, are expected to generate higher absolute demand for retrofit-related construction employment.

Using the available construction-sector data, we analyse the volume and the speed of each technology deployment at council area, extrapolating trends where necessary. These dimensions are then combined into a composite local indicator, weighted by the estimated employment share generated by each technology. This ensures that technologies with greater employment intensity (i.e. domestic retrofit) proportionately influence the overall spatial distribution.

In the transport sector, electric vehicle (EV) activity is allocated using historic Scottish council-area shares of total EV registrations (2009–2025). As discussed in Section 4.3, the principal driver of employment within the transport pipeline is EV maintenance, making the local distribution of EV uptake a critical determinant of local employment effects^[6].

Public EV charging infrastructure is allocated using historic (2019–2025) Scottish local authority data on public charge point deployment. As in the construction sector, we assess both the scale and growth rate of charging infrastructure. These are then integrated into a composite local indicator weighted by the relative employment contribution of each transport technology.

Evidence review and stakeholder workshop

As part of this work, we carried out an extensive and detailed review of existing evidence and research. This review helped develop the approach described above, and helped contextualise the demand-side analysis with evidence of supply-side frictions and barriers, such as recruitment difficulties, skills gaps, and supply pinch-points.

In addition to the evidence review, a series of workshops were held to engage with key construction and transport stakeholders (across government, industry and education) to validate the findings of the evidence review, and gather feedback and expert insights on the study’s approach.

Analysis of net zero workforce requirements: Transport

Context

This section outlines the current structure of employment in Scotland’s transport sector and the emerging workforce implications of the net zero transition. We draw on available evidence to assess the scale and composition of employment, the prevalence of green and transitioning occupations, and the key labour market pressures. We also examine the role of upskilling and reskilling in supporting the transition, alongside regional and sub-sectoral variation in workforce demand.

To provide context, Table 4 shows that Scotland’s transport sector employed 98,000 people in 2022, representing 3.8% of total employment (Skills Development Scotland, 2023). The table also highlights that over half of the workforce is employed in green occupations^{[7] [8]}, many of which are expected to experience increasing demand resulting from the transition to net zero.

Table 4: Transport employment (Skills Development Scotland, 2023)

Notes: (1) Increased demand refers to existing occupations having higher employment demand due to green activities, without substantial changes to tasks or worker requirements. (2) Enhanced skills and knowledge describes existing occupations where green activities significantly alter tasks, skills, knowledge, or credentials, while the core purpose of the role remains unchanged. (3) New and emerging occupations arise where green activities create entirely new or substantially transformed roles with distinct work and worker requirements (Dierdorff et al., 2009).

The transport sector differs from other CESAP sectors in having a broadly even split between green and non-green occupations. The high share of roles where green activities considerably alter tasks and skills suggests that the transition in transport will rely primarily on upskilling within existing roles. This pattern indicates adaptation rather than the creation of entirely new occupations. Moreover, these workforce patterns are not evenly spread across Scotland. Lanarkshire and the Glasgow Region accounted for 27% of the transport workforce in 2022, with Edinburgh, East and Midlothian, and Aberdeen City and Shire comprising a further 23% (Skills Development Scotland, 2023). This uneven distribution has important implications for the spatial alignment of skills supply and demand. In particular, as decarbonisation-related infrastructure expands into rural and island regions, workforce availability and training provision may also need to expand in these areas.

Short-term workforce pressures are already evident. For example, despite growing demand for EV maintenance, only 31% of garages currently have the skills to service electric or hybrid vehicles, highlighting a clear short-term skills gap (Skills Development Scotland, 2023). These pressures coincide with ambitious policy commitments, which accelerate demand for new skills. An example of this is the UK Government’s planned phase-out of new petrol and diesel vehicles by 2035. Decarbonisation is driving substantial upskilling and retraining needs across the sector. Whilst much of the transition is expected to occur through upskilling within existing occupations, the literature also suggests that additional workers will be required to meet rising demand associated with electrification and related infrastructure. Table 5 provides a summary of key findings from the literature on workforce demand, skills needs, and labour market trends associated with transport activities. It places a particular focus on the vehicle and equipment repair and maintenance pipeline highlighted in Section 4.2.

Table 5: Key findings on skills and workforce needs in net zero transport

These findings highlight that transport plays a central role in Scotland’s net zero transition, with increasing demand for green and transitioning occupations. Our review indicates that the workforce shift will rely primarily on upskilling and reskilling existing workers rather than large-scale occupational replacement. We also note that skills demand and workforce pressures vary considerably across regions and sub-sectors, creating challenges for targeted training and effective workforce planning. In the short term, we identify labour shortages in key roles such as electricians and infrastructure-related positions. These shortages coincide with ambitious decarbonisation timelines. Evidence suggests that longer-term employment growth will follow construction-led build‑out phases, before stabilising in operational and maintenance roles. Altogether, these results highlight the strong interconnection between transport and construction workforce needs throughout the transition.

Barriers to delivery and other considerations

Our review identifies multiple barriers that constrain the transport sector’s transition to net zero. These span workforce shortages, training gaps, structural issues, and diversity challenges.

Table 6: Workforce barriers constraining the transport sector’s transition to net zero

Net zero workforce requirements

This section examines projected employment levels in activities supporting the net zero transition in transport (vehicle and equipment repair and maintenance), with a focus on the EV pipeline identified above. We present results (a) at the occupational level, (b) by SSC‑defined skills, and (c) across regions.

Employment demand from net zero pathways

The Cambridge Econometrics April 2025 UK forecast estimates that employment in vehicle and equipment repair and maintenance activities will be 69,600 jobs in 2026, decreasing to 65,500 jobs by 2045 (Cambridge Econometrics, 2025).^[9] Whilst these projections suggest a modest decrease in employment in the sector, trends may differ across subsectors, with employment in some expected to increase. The projections also exclude explicit assumptions related to the UK’s green transition, including the EV pipeline discussed above. At the time the projections were produced, the UK had published a strategy for its path to reach net zero carbon emissions by 2050 (Department for Energy Security and Net Zero, 2021). While this strategy includes both specific investment commitments and aspirational or goal-based targets, they had not yet been budgeted for or implemented. The level of known planned investments was considered too small to materially affect the macroeconomic outlook (Cambridge Econometrics, 2025).

Consequently, the projections do not reflect more recent policy developments, such as the increased prioritisation of net zero targets and committed investment pipelines, including those associated with the Climate Change Committee’s carbon budgets for Scotland described in previous sections. They should, therefore, be interpreted as a baseline scenario rather than a representation of current policy commitments and planned investments.

Figure 1 shows the additional employment associated with more recent policy plans, particularly EV-related activities, such as charging points installation and vehicle maintenance. The figure indicates that 200 additional jobs will be required in 2026, rising to 2,800 jobs by 2045. These additional jobs are over and above the baseline projections presented earlier, which do not incorporate the effects of the net zero transition.

When combined with the baseline, this implies that total employment in vehicle and equipment repair and maintenance activities would be higher than projected under the baseline alone, partially offsetting the decline associated with conventional internal combustion engine (ICE) activities. These results point to a sustained increase in labour demand associated with the transition to net zero. The growth is driven by ongoing investment in EV technologies and supporting infrastructure. Demand remains elevated over time, reflecting the continuous maintenance requirements of electric vehicles and the expanding size of the EV fleet. This growth forms part of a structural shift, with increasing demand for EV-related jobs coinciding with a gradual decline in roles associated with ICE technologies.

These projections have important implications for workforce development in transport‑related activities. Baseline employment in vehicle and equipment repair and maintenance is projected to decline slightly over the long term. However, the expansion of EV-related activities is expected to increase demand for specific technical capabilities. This indicates that a growing share of the workforce will need to adapt existing mechanical skills to support electrified and digitally enabled vehicle systems. Meeting this demand will require targeted upskilling of the current workforce, particularly in areas such as: electrical systems, battery technologies, and digital diagnostic. Additionally, reskilling pathways that enable workers currently specialised in ICE technologies to transition into EV-related activities will be essential.

As discussed in Section 4, the employment projections are based on the technologies considered and the associated sectoral linkages. In this analysis, the sectoral linkages correspond to maintenance and repair of motor vehicles (SIC G45), and repair and installation of machinery and equipment (SIC C33). Consequently, the number of jobs projected in Figure 1 reflects all occupations associated with these activities (SIC G45 and SIC C33).

Figure 1: Projected additional employment in the transport sector under net zero pathways, 2026–2045. Source: Cambridge Econometrics. Own calculations

Occupations

While a large share of the employment generated is expected to be directly related to maintenance and repair activities, supporting occupations will also be required. These might include administrative, clerical, and secretarial occupations, providing supporting functions such as appointment scheduling, documentation management, and operational coordination.

At a more granular level, Figure 2 presents the additional projected employment levels across occupational groups involved in vehicle and equipment repair and maintenance. This provides insight into the skills required to fulfil net zero plans for the transport sector. These figures represent additional employment relative to the baseline projections, reflecting the impact of the net zero transition. Overall, employment in all occupational groups is projected to increase as a result of the net zero transition. In particular, skilled trades occupations are expected to account for the largest share of demand. Employment in these roles is projected to increase from 86 additional jobs in 2026 to a peak of 1,180 additional jobs in 2045.

Within skilled trades occupations, particularly strong employment growth is expected in roles associated with zero-emission (ZE) technologies. This growth reflects a transition within the occupation group, as increasing demand for ZE-related maintenance and repair is expected to occur alongside a decline in roles associated with ICE technologies.

Within skilled trades occupations, we expect the following roles associated with ZE-technologies to see particularly strong employment growth. This is expected to account for around 28.7% of the growth in the transport sector between 2026 and 2045:

• Vehicle technicians, mechanics and electricians (SOC code 5231)
• Vehicle body builders and repairers (SOC 5232)
• Telecoms and related network installers and repairers (SOC 5242)
• Electrical service and maintenance mechanics and repairers (SOC 5246)
• Welding trades (SOC 5213)

The second group of occupations in which notable employment growth is expected is sales and customer service occupations. Within this group, we expect the following roles to see particularly strong employment growth. This is expected to account for around 7.3% of the growth in the transport sector between 2026 and 2045:

• Vehicle and parts salespersons and advisers (SOC code 7115)
• Customer service occupations not elsewhere classified^[10]

Figure 2: Projected additional employment by occupational group. 2026-2045

Source: Cambridge Econometrics and Labour Force Survey (ONS). Own calculations

The results presented are based on the Climate Change Committee’s Balanced Pathway and other sources, which provide the technology deployment assumptions used to estimate workforce demand in this study. While alternative net zero trajectories may imply different levels of technology deployment and, therefore, different overall employment levels, the broad occupational patterns identified here are unlikely to change. This outcome reflects the fact that most decarbonisation pathways involve large-scale deployment of technologies such as electric vehicles and charging infrastructure, which require installation, operation, and maintenance activities across similar occupational groups. As a result, although the scale of employment may vary across scenarios, demand for occupations linked to technical trades, engineering, installation, and maintenance activities is expected to remain central to the net zero transition.

Skills

Figure 2, while informative, does not explicitly identify the specific skills that will be most in demand during the transition. To address this, we map the skills associated with vehicle and equipment repair and maintenance activities using the newly developed UK Standard Skills Classification (SSC). This provides a more granular understanding of the skills underpinning the net zero transition. As outlined in Section 4.4, the SSC enables both aggregated and disaggregated analyses of skills requirements.

Table 7 presents the skills projected to be in highest demand based on occupational requirements, uses the SSC taxonomy codes. Skills are ranked using a relevance index that combines the projected employment associated with each skill and its frequency within the SSC. This approach ensures that the index captures both the level of employment associated with each skill, and the extent to which it is required across occupations. In practice, skills linked to occupations with higher projected employment and those that are used across a wider range of roles receive higher relevance scores. This allows us to identify not only highly specialised skills, but also those that are widely required across the workforce. The table also distinguishes between Skill Domains (broad categories) and Skill Areas (more detailed classifications), providing a more granular view of skill requirements. This distinction is particularly useful for identifying priority areas for skills development and training.

Our findings indicate that the skill domains^[11] projected to be most relevant are:

• Evaluating and Inspecting (from 200 jobs in 2026 to 2,750 by 2045)
• Planning and Resourcing (from 170 to 2,300 jobs)
• Recording and Documenting (from 160 to 2,200 jobs)
• Advising and Supporting (from 150 to 2,100 jobs)
• Maintaining and Repairing (Physical Objects) (from 140 to 1,900 jobs)

At a more detailed level, Table 7 also shows that the most relevant areas include managing organisational and operational records, inspecting and testing structures and equipment, maintaining mechanical and pressurised equipment, evaluating and verifying information. Because the relevance index is derived from the occupational structure and the skills associated with each occupation in the SSC, the relative ordering of skills remains broadly stable over time. In practice, the results therefore indicate that the demand for these skills is expected to increase as employment in the relevant occupations grows, rather than reflecting the emergence of entirely new skills. This level of detail provides a clearer understanding of the specific capabilities required to support the net zero transition within the transport sector.

It is important to note that the table is not intended to identify entirely new skills. In many cases, what may appear to be new skills are in fact existing skills that are being applied or adapted to new technologies. The level of aggregation used in this analysis does not allow us to identify technology-specific skills in detail. For example, the maintenance of electric vehicles requires many of the same diagnostic, inspection, and mechanical maintenance skills traditionally used in servicing internal combustion engine vehicles, although these skills must be adapted to work with electric drivetrains, batteries, and high-voltage systems. Similarly, the installation of electric vehicle charging infrastructure relies on existing electrical installation and inspection skills, which are already used in construction and electrical engineering occupations. In this sense, technological transitions often involve the adaptation and recombination of existing capabilities rather than the creation of entirely new skill sets.

This interpretation is consistent with the broader literature on technological change and skills, which emphasises that many labour market transitions involve upskilling and the adaptation of existing competencies rather than the emergence of completely new skills (OECD, 2022). Evidence suggests that technological change frequently reshapes how skills are used within occupations, often requiring additional training or certification. It requires workers to update and apply existing capabilities in new technological contexts rather than replacing them entirely.

The results in Table 7 provide an indication of the skills most strongly associated with the occupations projected to grow as part of the net zero transition. The table uses SSC classifications to highlight the capabilities that are likely to become increasingly important as demand increases for occupations involved in vehicle and equipment repair and maintenance activities.

Table 7: Skills projected to be in highest demand based on occupational requirements. Source: Cambridge Econometrics and Labour Force Survey (ONS). Own calculations

The analysis can be further disaggregated. As an illustration, Table 8 and Table 9 present the skill requirements for skilled trades and sales and customer service occupations within the activities related to vehicle and equipment repair and maintenance. These are the two occupational groups expected to account for the highest levels of employment. The purpose of this table is to facilitate targeted training and workforce development initiatives tailored to the needs of each group.

The skills presented in Table 8 can be interpreted as bundles of capabilities associated with the occupational groups expected to have the highest employment demand. In the SSC framework, each occupation is linked to multiple skill areas that collectively describe the range of tasks performed within that occupation. As a result, the skills listed in Table 8 should be understood as groups of related competencies that tend to be required together within occupations belonging to the skilled trades and sales and customer service occupational groups.

For skilled trades occupations, the most relevant skill is maintaining mechanical and pressurised equipment, followed by inspecting and testing structures and equipment, evaluating and verifying information, maintaining electrical and electronic equipment, and installing mechanical and pressurised systems. These skills reflect the technical and operational nature of these roles.

Given the central role of skilled trades occupations, particularly, vehicle technicians, mechanics and electricians, in supporting the net zero transition in the transport sector, we analyse the information provided by the SSC at a more disaggregated level. This allows us to identify emerging skills, understood here as skills closely related to the transportation activities outlined in Section 4. Within this subset of skills, several capabilities can be linked to the growing adoption of new vehicle technologies and supporting infrastructure. These include skills related to EV and electrification technologies, such as maintaining electrical charging systems, installing vehicle batteries, and repairing battery components. In addition, advanced vehicle system skills are becoming increasingly relevant, including calibrating vehicle ADAS systems (Advanced Driver Assistance Systems) and inspecting electronic drive systems. The increasing digitalisation of vehicles also creates demand for skills related to digital and connected vehicle systems, such as diagnosing faults on industrial networks, diagnosing and repairing faults in vehicle management systems, and installing GPRS/GPS tracking systems. The growing integration of automated and intelligent systems in modern vehicles highlights the importance of automation and smart system skills, including finding faults in automation control systems and maintaining electrical control systems.

Finally, the analysis also captures a growing demand for electrical and high-voltage skills associated with the expansion of charging infrastructure. This is particularly relevant for heavy-duty vehicles and depot-based charging systems, which require higher-capacity electrical connections and, in some cases, upgrades to local grid infrastructure and substations. While these requirements are not explicitly identified as a separate category within the SSC, they are reflected in skill areas such as maintaining electrical and electronic equipment and installing electrical systems. In practice, this implies an increasing need for workers with advanced electrical competencies, including high-voltage installation, maintenance, and safety procedures.

Table 8: Skills projected to be most in demand for skilled trades and professional occupations. Source: Cambridge Econometrics and Labour Force Survey (ONS). Own calculations

In contrast, sales and customer service occupations (Table 9) place greater emphasis on providing advice on vehicles’ performance and safety; deliver sales presentations; inspect and assess vehicle damage; demonstrate products to customers; and manage customer relationships.

Table 9: Skills projected to be most in demand for sales and customer service occupations. Source: Cambridge Econometrics and Labour Force Survey (ONS). Own calculations

Regional analysis (Council areas)

As mentioned in Section 4.5, it is possible to derive indicative estimates of the labour market pressures council areas are likely to face by disaggregating national‑level evidence presented in this report. This can be done using additional data sources such as regional population projections published by the National Records of Scotland, among others.

In the case of the activities related to vehicle and equipment repair and maintenance, Table 10 shows projected increases in activity levels across all council areas, based on local EV uptake and infrastructure deployment patterns. These additional jobs correspond to employment associated with EV-related activities under the net zero transition. This indicates sustained growth across all council areas (consistent with national trends). Activity levels remain highest in larger urban areas such as Renfrewshire, Stirling, the City of Edinburgh, Glasgow City, and Fife. This pattern is expected to translate into high demand for a range of occupations associated with vehicle maintenance and repair, including vehicle technicians, mechanics and electricians; vehicle body builders and repairers; telecommunications and related network installers and repairers; electrical service and maintenance technicians; and welding trades.

Table 10: Projected additional employment supporting the transport sector under net zero pathways by council area and single year, 2026–2045. Source: Cambridge Econometrics and Section 4.5. Own calculations

In addition to the overall stock of vehicles, the pace of growth in both the vehicle fleet and charging infrastructure provides further insight into where demand pressures are likely to intensify. Historical trends indicate that there is rapid expansion in ULEV fleets and charging points in council areas such as Renfrewshire, Stirling, the City of Edinburgh, Glasgow City, and Fife. As a result, these areas are likely to face particularly strong labour market pressures, reflecting both the scale and the growth of demand for EV-related maintenance and repair services.

Analysis of net zero workforce requirements: Construction

Context

Drawing together the evidence reviewed, we highlight several consistent factors shaping the construction workforce in Scotland’s net zero transition. Construction sits at the centre of Scotland’s net zero delivery, underpinning energy efficiency upgrades, large‑scale retrofitting, low-carbon heat deployment, and renewable energy infrastructure. It is consistently identified as a critical enabler of progress across heat decarbonisation, solar deployment, and onshore wind. Across the literature, workforce demand is shown to be closely linked to the scale and pace of investment in these activities.

The tables presented in this section summarise key findings from the literature on workforce demand, labour market pressures, and skills needs in Scotland’s construction sector. The dimensions reported reflect the indicators available in the underlying evidence base, which vary across sources.

Table 11: Construction sector workforce demand and skills Pressures (CITB, 2025)

The evidence reviewed indicates that employment growth is being driven by major infrastructure and retrofit programmes, including rail electrification, renewable energy developments, and building retrofits. The strongest demand is consistently identified for civil engineers, road and rail construction operatives, and steel erectors and metal workers. Demand for these roles and construction project managers is expected to increase steadily through the second half of the decade (CITB, 2025).

Retrofit delivery emerges as a particularly substantial source of workforce demand. At the time the underlying evidence was produced in 2022, around 3,000 renewable heating systems were being installed in Scotland’s homes each year (Skills Development Scotland, 2023). Projections cited in the literature indicate that installation rates would need to increase rapidly to 124,000 systems per year, between 2021 and 2026 (see Table 12). They are expected to peak at over 200,000 installations per year in the late 2020s to meet anticipated regulatory requirements and energy efficiency standards. This implies substantial pressure on the construction workforce across all regions of Scotland.

Table 12: Projected installation rates of renewable heating systems (Skills Development Scotland, 2023)

Other net zero-related opportunities in construction are expected to expand rapidly across multiple sub-sectors (see Table 13).

Table 13: Projected Employment by low-carbon sub-sector (ClimateXChange 2022, 2024)

Construction employment is concentrated in the Glasgow Region, Aberdeen City and Shire, and Edinburgh, East and Midlothian. The evidence also points to marked regional variation in future workforce demand. For onshore wind, Dumfries and Galloway and Highland are projected to account for more than 20% of peak construction and installation workforce demand, while Highland is expected to face sustained demand for operations and maintenance roles into the late 2020s. Wider analysis for the Highlands and Islands suggests that net-zero construction employment could generate substantial, but uneven impacts through to 2040. These impacts will depend on policy choices, infrastructure investment, and grid constraints (HIE, 2025).

The skills profile of the construction workforce is shown to be evolving in response to these demands (Table 14).

Table 14: Key occupations, skills needs, employment trends and qualification levels for heat decarbonisation (Skill Development Scotland, 2024)

Overall, the evidence reviewed indicates that the construction sector faces a combination of strong near-term demand, high workforce churn, and rapidly evolving skills requirements. Employment growth is largely driven by time-limited build-out phases associated with net zero infrastructure, followed by more stable operational and maintenance roles. This evidence reinforces the need for coordinated workforce planning, targeted skills provision, and alignment between construction and related sectors, particularly between transport and energy sectors. This will be essential to support effective delivery of Scotland’s net zero ambitions.

Barriers to delivery and other considerations

Our review identifies a set of interconnected barriers that is limiting the construction sector’s ability to deliver Scotland’s net zero targets (see Table 15). Workforce supply is tightening, as large numbers of experienced workers approach retirement, and recruitment continues to lag behind demand. Training systems struggle to respond at pace, with long apprenticeship routes and limited fast-track options slowing skills supply. Provision has not kept up with rapidly evolving net zero technologies. This reflects both the time required to develop technical competencies through established entry level pathways and the limited capacity of existing training provision to scale rapidly in response to rising demand. As a result, even where new training opportunities are introduced, the process of developing a sufficiently skilled workforce can take several years.

These pressures are intensified in rural and island regions, where projects face persistent recruitment and accommodation constraints. At the same time, shortages in key trades, rising certification requirements, and limited training capacity restrict delivery further. Persistent gender imbalances, urban concentration of employment, and weak perceptions of decarbonisation careers compound these challenges and risk undermining a just transition.

Table 15: Workforce barriers to the construction sector’s transition to net zero

Net zero workforce requirements

This section examines employment levels in the construction sector and how they evolve over time under net-zero pathways. As described in Section 4, we focus on the effects of domestic retrofit and energy capacity expansion, including wind, solar PV, hydrogen, grid storage, and hydropower. Results are presented at the occupational level, by SSC-defined skills, and across regions.

Employment demand from net zero pathways

The Cambridge Econometrics April 2025 UK forecast estimates that employment in the construction sector will be 171,300 jobs in 2026, increasing to 180,800 jobs by 2045, reflecting growth in general construction activity (Cambridge Econometrics, 2025). Within this context, Figure 3 shows projected additional employment levels associated with technologies expected to be supported by the construction sector under net zero pathways (renewable energy installation and retrofit – Construction).

The projected additional employment demand in construction from the net zero transition in these technologies is estimated to be 2,000 jobs in 2026. This level is projected to double by 2027 and continue to increase steadily, reaching 13,800 jobs by 2035. This is expected to remain relatively stable, before decreasing from 2039 onwards, falling to 6,700 jobs by 2045. Despite this decline, demand in construction from the net zero transition in these technologies remains above initial levels, indicating a lasting structural increase in labour demand associated with the transition to net zero. These projections highlight the distinct phases of employment associated with the net zero transition: rapid early growth, subsequent stabilisation, and a later decline as technologies mature and deployment levels off.

These projections have important implications for workforce development in the construction sector. Overall employment in construction is expected to increase modestly over the long term. Activities linked to the net zero transition, however, are projected to expand more rapidly, particularly during the early deployment phases of low-carbon technologies. This indicates that a growing share of the workforce will need to adapt existing skills to support these activities. Key areas include renewable energy installation, building retrofit, and electrification infrastructure. Meeting this demand will require both upskilling of the current workforce and targeted reskilling to enable workers to move into emerging net zero-related activities. The rapid increase in demand during the early deployment phase also highlights the need for timely expansion of training provision. Such expansion is essential to prevent skills shortages in specialised construction activities.

Figure 3: Projected additional employment in the construction sector under net zero pathways, 2026–2045

Source: Cambridge Econometrics. Own calculations

Occupations

Figure 4 shows projected employment levels across occupational groups in the construction sector. Employment in all groups is expected to increase as a result of the net zero transition. Skilled trades occupations are expected to account for the largest share of additional jobs associated with the net zero pipeline, accounting for 1,150 jobs in 2026. Employment in this occupation is expected to increase substantially, peaking between 2034 and 2039 at 9,000 jobs per year. Demand is then expected to decrease to 4,300 jobs by the end of 2045.

Within skilled trades occupations, we expect the following roles to see particularly strong employment growth. This is expected to account for around 47% of the growth in the construction sector between 2026 and 2045.

• Carpenters and joiners (SOC code 5316)
• Electricians and electrical fitters (SOC 5241)
• Painters and decorators (SOC 5323)
• Plumbers and heating and ventilating installers and repairers (5315)
• Roofers, roof tilers and slaters (5314)

The second group of occupations in which there is expected to be strong employment growth is process, plant and machine operatives. Within this group, we expect the following roles to see particularly strong employment growth. This is expected to account for around 8.6% of the growth in the construction sector between 2026 and 2045:

• Scaffolders, stagers and riggers (SOC code 8151)
• Construction operatives n.e.c. (SOC 8159)
• Mobile machine drivers and operatives n.e.c. (SOC 8229)
• Large goods vehicle drivers (SOC 8211)

Professional occupations are also expected to see notable increases, particularly construction project managers and related professionals (SOC 2455) and civil engineers (SOC 2121).

Figure 4: Projected employment by occupational group. 2026-2045

Source: Cambridge Econometrics and Labour Force Survey (ONS). Own calculations

Skills

Figure 4 shows employment trends across occupations, indicating an increase in demand for technical, engineering, and project management skills. However, they do not directly identify the specific skills driving this demand. To address this, we map construction-related occupations to the SSC, providing a more detailed view of the skills required for the net zero transition.

Table 15 presents the skills expected to be in highest demand, ranked according to a relevance index (see Section 4.4). The results indicate that the most in-demand SSC Skill Domains are:

• Evaluating and Inspecting (from 1,900 additional jobs in 2026 to 6,600 by 2045)
• Planning and Resourcing (from 1,800 to 6,200)
• Operating & Monitoring (from 1,700 to 6,100)
• Constructing and Installing (from 1,500 to 5,500)
• Managing and Directing (from 1,500 to 5,500)

At a more detailed level, Table 16 highlights the SSC Skill Areas expected to be most in demand. These include: inspecting and testing structures and equipment; evaluating and verifying information; managing organisational and operational records; installing building interior systems and equipment; and determining project requirements and plans. Together, these results provide a more precise understanding of the specific skills needed to support the construction sector’s net zero transition.

Table 16: Skills projected to be in highest demand based on occupational requirements

Source: Cambridge Econometrics and Labour Force Survey (ONS). Own calculations

Table 17 and Table 18 present the skill requirements for (a) skilled trades occupations and (b) process, plant and machine operatives within the construction sector. These are projected to account for the largest share of employment demand. The tables highlight both shared and distinct skill requirements across the two occupational groups. Skilled trades occupations (Table 17) are characterised by a strong emphasis on installation, maintenance, and system integration. They also require key skills related to installing building interior systems, maintaining mechanical and electrical equipment, and planning and evaluating technical operations. These roles also require a combination of technical expertise and analytical capabilities, such as evaluating information, assessing risks, and determining project requirements.

Given the central role of skilled trades occupations in supporting the net zero transition in the construction sector, we analyse the information provided by the SSC at a more disaggregated level in order to identify emerging skills. These are understood to be those skills closely related to the construction activities, as outlined in Section 4. In particular, we focus on carpenters and joiners, and electricians and electrical fitters, given their relatively high employment concentration within the sector.

For carpenters and joiners, the skills associated with these occupations remain largely traditional construction skills, reflecting activities such as installing building components and working with structural materials.

In contrast, the skill set associated with electricians and electrical fitters shows a stronger connection to emerging technologies linked to the net zero transition. Within this subset of skills, several capabilities can be linked to the growing adoption of low‑carbon energy technologies and supporting infrastructure in the construction sector. These include skills related to renewable energy systems, such as installing solar energy systems, maintaining photovoltaic systems, calculating solar panel orientations, operating solar thermal energy systems for hot water and heating, installing inverters, and designing solar energy systems. The transition towards smart energy and grid systems also creates demand for skills such as designing smart grids, monitoring green energy systems, and directing renewable energy production operations. Finally, the growing integration of smart buildings and digital energy technologies highlights the importance of skills such as installing Building Energy Management Systems (BEMS) wiring systems, installing smart home devices, and providing advice on smart home technologies. Alongside these developments, the increasing emphasis on energy efficiency and sustainability requires capabilities such as conducting energy audits and providing advice on energy-saving technologies and strategies to reduce utility consumption.

Table 17: Skills projected to be most in demand for skilled trades occupations

Source: Cambridge Econometrics and Labour Force Survey (ONS). Own calculations

In contrast, process, plant and machine operatives (Table 18) are more strongly associated with operational and task-based activities. Key skills include handling and moving materials, operating machinery and vehicles, and monitoring equipment and safety systems. These occupations place greater emphasis on physical and procedural skills and the safe, efficient operation of equipment. These differences underline the need for tailored training and workforce development strategies for each occupational group.

At the same time, there are skills areas of overlap between the two occupational groups, particularly in skills such as inspecting and testing structures and equipment, installing systems, and maintaining machinery. This overlap reflects the interconnected nature of construction activities, where both technical installation and operational execution are required.

Table 18: Skills projected to be most in demand for process, plant and machine operatives

Source: Cambridge Econometrics and Labour Force Survey (ONS). Own calculations

Regional analysis (Council areas)

Table 19 presents projected employment requirements in construction by council area, associated with the net zero technology pipeline. The largest projected additional demand is concentrated in the main population centres, particularly Glasgow City, City of Edinburgh, Fife, South Lanarkshire, and North Lanarkshire. Given the national occupational structure, this pattern is expected to generate high demand for key construction occupations, including carpenters and joiners; electricians and electrical fitters; painters and decorators; plumbers, and heating and ventilating installers and repairers; and roofers, roof tilers, and slaters.

Table 19: Projected additional employment in the construction sector under net zero pathways by council areas and single year, 2026–2045. Source: Cambridge Econometrics and Section 4.5. Own calculations

In addition to population size, projected growth trends in retrofit and energy-related activity provide further insight into where construction demand is likely to expand most rapidly. Our analysis suggests that there is expected to be relatively strong growth in construction activities in areas such as the Scottish Borders, Stirling, Dundee City, the Highland council area, and Fife. As a result, these areas may face particularly acute labour market pressures, driven both by rising demand and by the need to expand the local skills base to support the transition.

Potential skills cross-over between sectors

Overlaps between construction and transport sectors

Sections 5.2 and 6.2 identify the occupations and skills expected to be most in demand to support net zero objectives within the transport and construction sectors. These sections highlight a degree of overlap between the sectors in relation to required occupations and skills.

In particular, the occupations common to both sectors include:

• Telecoms and related network installers and repairers (SOC code 5242), accounting for 1.8% of employment in transport-related net zero activities and 2.5% in construction-related activities.
• Electricians and electrical fitters (SOC 5241) accounting for 1.7% of employment in transport-related net zero activities and 10.8% in construction-related activities.
• Engineering technicians (SOC 3113), accounting for 1.0% of employment in transport-related net zero activities and 1.1% in construction-related activities.
• Production managers and directors in manufacturing (SOC 1121), accounting for 1.5% of employment in transport-related net zero activities and 0.7% in construction-related activities.

Several specific skills are common to both sectors. Among the most relevant are:

• Managing organisational and operational records (SSC code SA.095)
• Inspecting and testing structures and equipment (SSC SA.071)
• Maintaining mechanical and pressurised equipment (SSC SA.100)
• Evaluating and verifying information (SSC SA.077)
• Advising and supporting on legal issues, processes and disputes (SSC SA.062)
• Maintaining electrical and electronic equipment (SSC SA.104)
• Procuring and managing supplies (SSC SA.019)
• Documenting interviews and compiling reports (SSC SA.094)
• Leading organisational operations and improvements (SSC SA.082)
• Analysing and interpreting information and data (SSC SA.004)
• Installing mechanical and pressurised systems and equipment (SSC SA.029)
• Installing electrical and electronic systems and equipment (SSC SA.030)
• Determining project requirements and plans (SSC SA.018)

This overlap indicates that a subset of technical and engineering occupations is transferable between the two sectors, suggesting scope for labour reallocation to address emerging skill needs. At the same time, it may also generate cross-sector competition for workers with these skills, particularly where supply is constrained. The extent of mobility and competition will depend on the degree of task similarity across sectors, and the availability of targeted training to bridge sector-specific requirements.

Overlaps with other sectors

To broaden the analysis, we analyse the structure of the SSC to identify potential cross‑sectoral overlaps and sources of labour for construction and transport activities supporting net zero. The SSC identifies the skills that are most relevant to specific industry activities (SIC), allowing us to examine how essential skills are distributed across sectors. Using this framework, we identify where essential skills in construction and in transport‑related net zero activities are shared with other sectors. This allows us to highlight potential areas for labour mobility that could support Scotland’s net zero transition.

Transport-related activities supporting the net zero transition

Table 20 shows the extent to which the skills required for transport-related net zero activities are also used in other sectors of the economy. Darker shading indicates a greater degree of shared skills. Shared skills across sectors indicate potential labour mobility between sectors, as workers with comparable skill sets may move between activities as demand evolves. At the same time, shared skill requirements may also create competition for workers across sectors, particularly in occupations where the supply of skilled labour is limited.

The first column of Table 20 lists the skill domains, while the second column reports the number of essential skills within each domain for the construction sector. For example, within the ‘designing and creating’ domain, five key skills are identified: create construction or installation diagrams; design industrial processing systems; create electrical diagrams; produce ultra-precision mechanical systems; and design mechanical equipment.

The remaining columns indicate the extent to which these essential skills are present in other sectors. For instance, two of the “designing and creating” critical skills identified in the transport-related activities are also found in the construction sector. Similarly, within the “researching and analysing” domain three of the skills are also mapped to the manufacturing sector.

Table 20: Cross-sectoral overlap in skills associated with transport-related activities supporting the net zero transition. Source: Standard skills classification (SSC). Own calculations

Notes: (1) Other sectors include: mining and quarrying, electricity, gas, steam and air conditioning supply, wholesale and retail trade; repair of motor vehicles and motorcycles, transportation and storage, accommodation and food service activities, information and communication, financial and insurance activities, real estate activities, administrative and support service activities, public administration and defence; compulsory social security, education, human health and social work activities, arts, entertainment and recreation, water supply; sewerage, waste management and remediation activities, other service activities, activities of households as employers, activities of extraterritorial organisations and bodies.

Table 20 reveals a varied pattern of cross-sectoral skills overlap across the skill domains associated with transport-related net zero activities. The highest levels of overlap are observed in technically oriented domains. Within the skill domain of evaluating and inspecting, which represents one of the largest groups with 38 essential skills, there is a high degree of cross-sectoral overlap. 18 of these skills are also present in manufacturing, 16 skills in professional, scientific and technical activities, and eight in construction, with a smaller share (seven skills) found in other sectors. Similarly, operating and monitoring skills exhibit a high degree of overlap with manufacturing (23 skills).

Skills related to designing and creating show substantial alignment with both manufacturing and professional, scientific and technical activities (four key skills in each case). Researching and analysing skills are strongly represented in professional activities (six skills) and, to a lesser extent, manufacturing (three skills).

These patterns indicate that technical, engineering, and operational competencies are highly transferable across sectors, particularly between transport-related activities and manufacturing.

Construction related activities supporting the transition

Table 21 presents the results of potential cross-sectoral overlaps for the construction sector. The first column lists the Skill Domains, while the second column reports the number of essential skills within each domain for the construction sector. For example, within the ‘researching and analysing’ domain, two key skills are identified: reading and interpreting technical instructions, and conducting environmental health investigations.

The remaining columns indicate the extent to which these essential skills are present in other sectors. Darker shading represents a higher degree of overlap. For instance, nine of the ‘designing and creating’ critical skills identified in the construction sector are also found in manufacturing. Similarly, within the ‘constructing and installing’ domain (which represents a core area of construction activity in terms of number of skills), 23 of the skills are also mapped to the manufacturing sector.

Table 21: Cross-sectoral overlap of construction skills. Source: Standard skills classification (SSC). Own calculations

Notes: (1) Other sectors include: mining and quarrying, electricity, gas, steam and air conditioning supply, wholesale and retail trade; repair of motor vehicles and motorcycles, transportation and storage, accommodation and food service activities, information and communication, financial and insurance activities, real estate activities, administrative and support service activities, public administration and defence; compulsory social security, education, human health and social work activities, arts, entertainment and recreation, other service activities, activities of households as employers, activities of extraterritorial organisations and bodies.

The results indicate a considerable degree of skills overlap between the construction sector and other sectors in the economy, indicating strong potential for cross-sectoral labour mobility to support the net zero transition. Manufacturing emerges as a key source of transferable skills, with high levels of overlap in domains such as constructing and installing (23 skill out of 106 key skills), designing and creating (9 skills), operating and monitoring (14 skills), and evaluating and inspecting (9 skills). This indicates that workers in manufacturing may possess relevant technical and operational capabilities that could be redeployed to support construction‑related net zero activities.

There is also notable overlap with professional, scientific and technical activities, particularly in higher-level and analytical skill domains. For example, more than half of the skills in designing and creating (10 skills) and nearly half in evaluating and inspecting (11 skills) are shared with this sector.

Sectors such as water supply, sewerage, waste management and remediation activities also show meaningful overlap in specific domains, particularly in evaluating and inspecting (six key skills) and designing and creating (six skills).

Whilst these overlaps suggest potential for labour mobility, the extent to which workers can transition between sectors will depend on the availability of effective reskilling pathways. In practice, transitions across sectors may require additional qualifications, sector-specific experience, or certification requirements, which can limit the speed at which workers redeploy their skills. Industry norms and regulatory frameworks may also constrain mobility if they do not readily recognise transferable skills or alternative pathways into occupations. As a result, even where transferable skills exist, additional training and structured entry pathways may be needed to enable workers from related sectors to move into new roles.

Conclusion

This report assesses the workforce and skills needed as Scotland transitions to net zero in the construction and transport sectors. Using a technology-driven analytical framework, the study translates projected deployment of key net zero technologies into employment demand by sector, occupation and skill. The analysis draws on the Climate Change Committee’s Balanced Pathway scenario, alongside other evidence and modelling assumptions. It focuses on major transition activities such as renewable energy deployment, domestic retrofit, electric vehicle adoption and related infrastructure.

The results indicate that the net zero transition will generate sustained employment demand across both construction and transport-related activities. However, the timing and scale of this demand will vary between sectors. Demand is expected to start increasing in the late 2020s, with the greatest pressures emerging through the 2030s. This may leave a relatively short period to expand training and reskilling opportunities before demand peaks.

Construction employment demand is expected to increase rapidly in the early stages of the transition, driven by large-scale infrastructure deployment and domestic retrofit programmes. Demand is projected to peak in the mid‑2030s before gradually declining as major deployment phases are completed. However, employment is expected to remain above current levels, indicating a lasting increase in workforce demand. In transport-related activities, the transition is expected to change the type of jobs required rather than lead to substantial overall employment growth. Demand for roles linked to zero-emission technologies, including electric vehicle maintenance and charging infrastructure, is expected to increase steadily. Activities related to internal combustion engine technologies are expected to gradually decline.

The scale of this transition is substantial relative to current workforce capacity. Much of the adjustment is expected to occur through upskilling within existing roles. However, rising demand for technical occupations coincides with existing shortages in key areas, including electrical and mechanical skills. This suggests that current training provision may not be sufficient to meet future demand without further expansion.

Skilled trades are expected to account for the largest share of workforce demand across both sectors. In transport-related activities, key occupations include vehicle technicians, mechanics, electricians, electrical service and maintenance technicians, and welding trades. In construction, prominent occupations include carpenters and joiners, electricians and electrical fitters, plumbers and heating installers, painters and decorators, roofers, process and machine operatives, and professional roles such as civil engineers and construction project managers.

The analysis shows that many of the skills needed for the net zero transition already exist within the workforce, but will need to be adapted to new technologies and ways of working. Across both sectors, the most relevant skill areas include evaluating and inspecting, planning and resourcing, recording and documenting, and maintaining and repairing equipment. New skills will also be needed as electrification, digitalisation and low-carbon energy systems become more widely used. In transport, these include skills related to electric vehicle systems, battery technologies, digital diagnostics, and automated control systems. In construction, they include skills related to renewable energy systems, smart building technologies, and energy efficiency solutions – including the installation and maintenance of solar systems, and building energy management systems. Importantly, demand for these skills is expected to intensify over the 2030s, in line with peak deployment across both sectors. This highlights the need to align training provision with expected demand.

Finally, the analysis highlights substantial overlap between the occupations and skills required across construction and transport. Technical occupations such as electricians, engineering technicians, and telecommunications installers are required across both sectors and in other parts of the economy. This reflects the shared infrastructure and technologies that support the net zero transition. The overlap creates opportunities for workers to move between sectors, but could increase competition for people with similar technical skills.

References

Centre for Sustainable Road Freight. (2025). Towards Zero Emission HGV Infrastructure in Scotland: Phase 2 Report . Click or tap here to enter text.

Cardenas Rubio, J., Warhurst, C., Anderson, P., Jeisson, D., & Rubio, C. (2022). Green Jobs in Scotland: An inclusive approach to definition, measurement and analysis. https://warwick.ac.uk/fac/soc/ier

Cambridge Econometrics. (2025). MDM-E3 Annual Economic Forecast: Unpublished.

Cirillo, V., Fanti, L., Mina, A., & Ricci, A. (2023). The adoption of digital technologies: Investment, skills, work organisation. Structural Change and Economic Dynamics, 66, 89–105. https://doi.org/10.1016/j.strueco.2023.04.011

CITB. (2025). Construction Workforce Analysis Scotland 2025 – 2029. Retrieved from https://www.citb.co.uk/cwo/index.html

ClimateXChange. (2022). Clean Heat and Energy Efficiency Workforce Assessment. https://doi.org/10.7488/era/2524

ClimateXChange. (2024). Workforce and skills requirements in Scotland’s onshore wind industry. Retrieved from https://www.climatexchange.org.uk/projects/workforce-and-skills-requirements-in-scotlands-onshore-wind-industry/

ClimateXChange. (2024). Workforce and skills requirements in Scotland’s solar industry. Retrieved from https://www.climatexchange.org.uk/projects/workforce-and-skills-requirements-in-scotlands-solar-industry/

Department for Energy Security and Net Zero. (2021). Net Zero Strategy: Build Back Greener. In Gov.Uk (Issue October). https://www.gov.uk/government/publications/net-zero-strategy

Department for Transport. (2026). Consultation on a New Heavy Goods Vehicle CO₂ Emissions Regulatory Framework for the United Kingdom. https://assets.publishing.service.gov.uk/media/6983430d13622473b51ca9db/new_hgv_co2_emissions_regulatory_framework_for_UK.pdf

Energy and Climate Change Directorate. (2025). Just Transition: draft plan for transport in Scotland: Annex B. In https://www.gov.scot/publications/ecosystem-restoration-code-engagement-paper/. https://www.gov.scot/publications/transition-draft-transition-plan-transport-scotland/

HIE. (2025). Regional Transformational Opportunities in the Highlands and Islands. Retrieved from https://www.hie.co.uk/media/kr3jjbdf/regional-transformational-opportunities-in-the-highlands-and-islands-report-may-2025.pdf

OECD (2022), Skills for the Digital Transition: Assessing Recent Trends Using Big Data, OECD Publishing, Paris,

https://doi.org/10.1787/38c36777-en.

Optimat. (2021). Skills for low carbon Heavy Duty Vehicles. Retrieved from https://www.transport.gov.scot/media/50464/skills-for-low-carbon-hdvs-pdf.pdf

Optimat. (2023). Skills for transport decarbonisation.

Scottish Enterprise. (2024). Economic Impact Scenarios for Scotland’s Energy Transition. Retrieved from https://www.scottish-enterprise.com/media/1ykbucca/the-economic-impact-of-scotlands-energy-transition.pdf

Skill Development Scotland. (2024). Sectoral Skills Assessments. Construction. Retrieved from https://www.skillsdevelopmentscotland.co.uk/media/rleiealf/sectoral-skills-assessment-construction.pdf

Skills Development Scotland. (2020). Climate Emergency. Skills Action Plan 2020-2025 Key Issues And Priority Actions.

Skills Development Scotland. (2023). CESAP Pathfinder. A Dynamic Skills Response to Supporting the Transition to Net Zero. Work Package 1: An Evidence Based Approach to Supporting the Transition to Net Zero. Retrieved from https://www.skillsdevelopmentscotland.co.uk/media/5hcorb5t/cesap-pathfinder-wp1-report.pdf

Skills Development Scotland. (2024). Climate Emergency Skills Action Plan (CESAP) Pathfinder. Final Project Report. Work Package 2. Retrieved from https://www.skillsdevelopmentscotland.co.uk/media/ucmjsq3y/cesap-wp2-final-report.pdf

Appendices

SOC 2020 definitions

The SOC 2020 (Standard Occupational Classification 2020) is the UK’s official system for classifying occupations based on the type of work performed and the skills required. It groups jobs into a hierarchical structure of major, sub-major, minor, and unit groups, enabling consistent analysis and comparison of occupational data across labour market statistics, surveys, and policy research (see Table 22).

Table 22: Standard Occupational Classification (SOC)

Source: ONS

The Structure of the UK Standard Skills Classification (SSC)

The SSC is structured as a hierarchical framework covering 3,343 individual skills needed to perform specific job tasks competently. Each occupational skill is connected to a range of tasks and core skills, where core skills represent broader, transferable capabilities that underpin effective task performance (see Figure 5).

Figure 5: Structure of the Skills Standard Classification

Source: Department for Work and Pensions (DWP) – Skills England

How to cite this publication:

Patel, S. et al. (2026) ‘Workforce requirements for net zero in transport and construction’, ClimateXChange. DOI https://doi.org/10.7488/era/7189

© The University of Edinburgh, 2026
Prepared by Cambridge Econometrics on behalf of ClimateXChange, The University of Edinburgh. All rights reserved.

While every effort is made to ensure the information in this report is accurate as at the date of the report, no legal responsibility is accepted for any errors, omissions or misleading statements. The views expressed represent those of the author(s), and do not necessarily represent those of the host institutions or funders.

This work was supported by the Rural and Environment Science and Analytical Services Division of the Scottish Government (CoE – CXC).

ClimateXChange

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If you require the report in an alternative format such as a Word document, please contact info@climatexchange.org.uk or 0131 651 4783.

1. Including vehicle and equipment repair and maintenance. ↑
   

2. Loft insulation is modelled as a one-off energy efficiency measure with a 40-year lifetime. The CCC assumes that most eligible homes receive loft insulation during the late 2020s and early 2030s, after which little additional deployment is required. As a result, data for this measure may show no further growth or may be absent in later years. ↑
   

3. At the time of reporting, the data referred to charge points. However, following a UK-wide methodology change introduced by the Department for Transport (DfT) and Zapmap on 26 February 2026, the headline metric now counts “EV chargers” instead. As some charge points, particularly rapid and ultra-rapid, can charge more than one vehicle simultaneously, this new measure better reflects overall network capacity and aligns with international standards. The Scottish Government is currently reviewing the implications of this change. ↑
   

4. It should be noted that these estimates are based on technical labour requirements and may not fully capture factors such as downtime, training, administrative tasks, and other non-operational activities, which could lead to an underestimation of total workforce needs. ↑
   

5. https://www.gov.uk/government/publications/uk-standard-skills-classification-interim-development-report/the-uk-standard-skills-classification ↑
   

6. This approach is applied across all vehicle types in the pipeline, including heavy goods vehicles and buses. However, the spatial allocation is based on EV registration patterns, which are largely driven by cars and light vans. As a result, the geographic distribution of HGV and bus activity is approximated using these patterns and may not fully reflect their distinct operational and infrastructure requirements. ↑
   

7. Green jobs are occupations affected by the greening of the economy and may take the form of new and emerging roles, existing jobs requiring substantial changes in tasks and skills, or occupations experiencing rising demand (Cardenas Rubio et al., 2022) ↑
   

8. This definition captures the number of people working in occupations potentially affected by the greening of the economy. It includes both existing occupations that may undergo transformation due to the green transition and newly emerging occupations (often referred to as pure green jobs). Importantly, not all workers within these occupations necessarily carry out green-related activities. ↑
   

9. Cambridge Econometrics (CE) develops annual economic forecasts for all twelve nations and regions (Wales, Scotland and Northern Ireland, and the nine regions of England) in the UK. The forecasts are developed using CE’s Multi‑Sectoral Dynamic Model (MDM-E3) of the UK economy. ↑
   

10. This category includes roles such as complain handler, helpdesk operator, etc. ↑
    

11. In the SSC, skill domains represent broad groupings of related skills, capturing the main types of activities performed within occupations. Each domain contains several more detailed skill areas, which describe specific capabilities required to perform particular tasks. Identifying the most relevant domains, therefore, provides an overview of the types of capabilities most strongly associated with the projected employment demand, before examining the more detailed skill areas within each domain. ↑
    

    
    

Low-carbon hydrogen is expected to play an important role in helping Scotland reach net zero, particularly in sectors where electrification is difficult, such as heavy industry, shipping and aviation. Understanding how hydrogen deployment could develop under different policy, market and technology conditions is essential for planning this transition.

This research develops a new hydrogen deployment model for Scotland. The model provides Scottish Government with a flexible tool to explore how different assumptions affect hydrogen demand and the infrastructure needed to support it through to 2050.

This report explains how the model was developed and demonstrates its use through two illustrative scenarios:

• Pragmatic scale-up reflects a future where hydrogen use grows steadily, but demand remains the main constraint.
• Industry breakthrough reflects stronger policy support, greater export growth and wider use of hydrogen in sectors where cutting greenhouse gas emissions is particularly challenging.

Key findings

• The report recommends continuing to develop the model as Scotland’s hydrogen sector evolves and using it alongside further analysis of infrastructure costs and future market conditions.
• The model is designed to test different future scenarios and support evidence-based decision making, rather than predict a single outcome.
• In both scenarios, exports drive most of Scotland’s hydrogen demand, with domestic demand led by shipping, aviation, steel and the chemical industry.
• Affordable electricity and timely investment in export infrastructure are the two biggest factors influencing hydrogen deployment. Delays to pipeline connections with the rest of the UK and Europe could significantly limit Scotland’s ability to grow its hydrogen sector and access international markets.
• The findings highlight the need for coordinated policy, competitive electricity prices and investment in export infrastructure to support hydrogen deployment.

For further information, please read the full report.

If you require the report or annex in an alternative format, such as a Word document, please contact info@climatexchange.org.uk or 0131 651 4783.

Page image: Bruno at Unsplash

Research complete March 2026

DOI: https://doi.org/10.7488/era/7184

1. Executive summary

Low-carbon hydrogen has been identified as a critical enabler of the transition to net zero. This is particularly the case in sectors where electrification is technically or economically constrained, such as heavy industry, shipping, aviation, and export markets. Achieving this ambition requires transparent, evidence-based analytical tools that can translate policy assumptions into credible deployment trajectories.

This report presents the findings of a research project commissioned by ClimateXChange (CXC) and the Scottish Government to develop a quantitative hydrogen deployment model for Scotland. The project responds to the need for an updated evidence base on Scotland’s hydrogen potential in light of significant policy, market, and technological developments since the 2020 Scottish Hydrogen Assessment (SHA).

As part of the project, we have created a flexible, user-configurable modelling tool. The model allows Scottish Government and Scottish Enterprise to explore how different policy, economic, infrastructure, and market conditions affect the pace and scale of hydrogen deployment across Scotland’s key sectors through to 2050. We used two illustrative deployment scenarios to test the model’s functionality and represent distinct and plausible futures for Scotland’s hydrogen sector.

The low-carbon hydrogen deployment model

The model is a scenario-based analytical tool for estimating hydrogen demand across Scotland’s key sectors through to 2050. It also estimates the supply-side infrastructure required to meet that demand. The model provides a quantitative, user-friendly framework for translating policy, economic, and technological assumptions into sector-level hydrogen demand projections and infrastructure requirements. It can be used to explore alternative deployment pathways, test key assumptions and support evidence-based decision-making.

The model itself, accompanied by a detailed user guide, was developed for use, and continued development, by Scottish Government and Scottish Enterprise analysts. This report summarises the process of its development and documents its use in testing two scenarios. The model is intended to support scenario testing and exploration of alternative futures, rather than provide a single forecast of Scotland’s hydrogen deployment trajectory. Results should therefore be interpreted as conditional on the policy, market and infrastructure assumptions specified within each scenario.

Two scenarios for hydrogen deployment in Scotland

The first scenario, ‘pragmatic scale-up’, is broadly aligned with the International Energy Agency (IEA) Stated Policies Scenario (STEPS). It reflects a world in which hydrogen grows but demand remains the binding constraint. The second, ‘industry breakthrough’, moves closer to an IEA Net Zero Emissions (NZE) trajectory. It is characterised by centralised infrastructure, high shipping and aviation targets, reliance on green hydrogen, and export development. It is a scenario in which hydrogen becomes a structural pillar of Scotland’s industrial sectors where reducing greenhouse gas emissions is particularly challenging.

Under Scenario 1, total hydrogen demand in Scotland reaches 40.2 TWh by 2050. This is underpinned by 11 GW of green and 135 MW of blue installed production capacity. Exports, (both pure hydrogen flows and derivatives such as ammonia and e-fuels), account for the majority of demand. Domestic consumption is led by shipping, aviation (including sustainable aviation fuels (SAF)), the steel sector, and the chemical industry.

Under Scenario 2, total demand reaches 70.3 TWh by 2050, served by 19.4 GW of green and 0.12 GW of blue production capacity. Exports again represent the largest single component of overall demand, with higher transport sector demand reflecting a more ambitious policy environment.

When considered alongside existing Scottish and UK hydrogen studies, both scenarios are above the most conservative projections and broadly in line with mid-range reference cases. However, they sit below the Scottish Government’s previous headline production ambitions and the most optimistic SHA scenarios.

Implications for hydrogen deployment

The model’s outputs are most sensitive to two parameters: electricity prices and the availability of export infrastructure. Electricity prices directly govern the business case for electrolytic green hydrogen production. The availability of export infrastructure acts as a hard boundary on whether Scotland can access international hydrogen demand. These findings are consistent with the broader literature and reinforce the relevance of both affordable renewable electricity and infrastructure.

We highlight several priorities for policy and investment.

• Targeted policy support to enable a competitive electricity price is essential for driving deployment and hydrogen competitiveness.
  
• Export infrastructure deserves early and decisive attention. Both scenarios show that exports drive the majority of Scotland’s hydrogen demand, yet export volumes are acutely sensitive to whether pipeline connections to the rest of the UK and the EU are available on time. Delays to these infrastructure routes are shown to significantly constrain overall system scale or alternatively cause sunk investments. The case for accelerating planning, consenting, and investment in inter-UK and EU cross-border hydrogen infrastructure is therefore strong.

This report and model should be treated as a first analytical layer. It focuses on demand-driven deployment under policy and infrastructure conditions and only considers electricity price conditions as a competitiveness cost-related input. No infrastructure deployment cost drives the deployment of hydrogen infrastructure in the model. Further work is recommended to evaluate the total system deployment costs of each scenario, carry out deeper sensitivity analyses, and update the model as Scotland’s hydrogen market continues to evolve.

Glossary/Abbreviations table

2. Introduction

This report presents the findings of research on the development of a hydrogen deployment model to support policymaking. The research was carried out by Ramboll on behalf of ClimateXChange and the Scottish Government.

Low carbon hydrogen has been identified as a cornerstone of Scotland’s transition to net zero by 2045. This project responds to the need to update the 2020 Scottish Hydrogen Assessment in light of significant policy, market, and technological developments.

Hydrogen is increasingly recognised as a critical enabler of decarbonization across multiple sectors. It is seen as particularly important in industry, long-haul transport, and for process heat, where electrification may be less feasible.

Scotland’s Hydrogen Action Plan (Scottish Government, 2022) sets out ambitions for 5 GW of installed hydrogen production capacity by 2030 and 25 GW by 2045, with a strong emphasis on export potential to Europe. This aligns with the UKG’s ambitions of developing low carbon hydrogen capacity for use in key sectors as outlined in the Hydrogen Strategy update to the market (DESNZ, 2025). Alongside the EU’s REPowerEU initiative (EU Commission, 2026), these strategies collectively signal a growing cross-border demand for clean hydrogen. The Scottish Government’s Hydrogen Sector Export Plan (Scottish Government, 2024) highlights the importance of international competitiveness, underpinned by robust certification and emissions accounting.

3. Methodology

This research was built on three complementary workstreams:

• Literature review: gathering key data and insights to inform model building, assumptions, and scenarios. This ensured an up-to-date technical and policy basis for model development. It delivered inputs for the assumptions, and created a foundation for scenario development. The review covered Scottish and UK policy and strategy documents (including the Scottish Hydrogen Action Plan (Scottish Government, 2022), UK Hydrogen Strategy updates (UK Government, 2022-2025), Clean Power 2030 Action Plan (UK Government, 2024), and relevant low-carbon hydrogen standards and business model frameworks), Scottish technical and market studies, and international benchmarks such as IEA scenarios (including STEPS/CPS) (IEA, 2025) and other public sources. The review was used to define baseline assumptions and parameters, including technology costs, deployment timelines, policy milestones, demand drivers, and key interdependencies across the hydrogen value chain. The outcome of the review feeds into Section 4.1and provides a structured evidence base for modelling choices, scenario narratives, and stakeholder discussions.
  
• Deployment model development: constructing a dynamic hydrogen deployment scenario model that allows for pathway generation based on different scenario configurations. This addressed the core of the research and delivered the modelling tool that then allows for scenario analysis and exploration of deployment alternatives. Model development included: (i) defining the overall model structure and interlinked input/output sheets; (ii) generating modules and dependencies across hydrogen production, demand, infrastructure, and exports; (iii) identifying and implementing parameters and assumptions; (iv) building a dashboard for user-friendly configuration and output interpretation; and (v) testing and calibration of model functionality. The model captures key relationships such as conversion of supply targets into capacity, links between capacity and build times, infrastructure implications of policy targets, and dependencies between hydrogen production buildout and grid needs. A short description of the model is provided in Section 4, with results generated through annual trajectories to 2050.
  
• Scenario specification: creation of two distinct scenarios for analysis. This collected the necessary data and variations to create different pathways for hydrogen deployment (summarised in Section 3.2). The scenarios were then used in the deployment model to generate results on the future hydrogen sector in Scotland (Section 5). Scenario design was based on the literature review, related studies, and project experience. Each scenario includes (i) a narrative describing the underlying assumptions and drivers, and (ii) parameter settings for production, demand, infrastructure, exports, and policy/enablers. The two scenarios are aligned with IEA, UK Government, and Scottish Government policy ambitions and targets. These scenarios demonstrate model functionality and provide a basis for deeper sensitivity analyses on the parameters that most strongly influence hydrogen deployment outcomes.
  

4. Literature review and data

The scope of the study required a deep literature review to establish necessary understanding of the Scottish context and extract relevant data sources. The following sections provide the findings of the review on the Scottish energy landscape and the relevant documents used for model development. We then summarise the two scenarios that were established from the literature review. These scenarios serve as case studies for use of the deployment model.

The Scottish energy landscape

The literature review was used to establish the system context, policy boundaries, and credible deployment pathways for the Scotland hydrogen deployment model before populating detailed technical parameters. In practice, these sources informed (i) the model scope and scenario logic, (ii) the demand sectors and infrastructure pathways represented in the model, and (iii) the policy/commercial assumptions used to interpret results. This was particularly important because hydrogen deployment in Scotland is shaped not only by local resource potential, but also by UK market support frameworks, certification rules, export readiness, and wider European/international market development. The section below sets out the key documents that were used to inform the model design.

At the Scotland level, the Scottish Hydrogen Action Plan (Scottish Government, 2022) provides the primary strategic baseline for domestic and export ambition. This includes the headline production ambition (5 GW by 2030 and 25 GW by 2045) and the broader framing of hydrogen as both a decarbonisation and industrial opportunity. It was used to identify the main demand segments and deployment themes relevant to the model (industry, transport, power system integration, exports, regional clusters/hubs, and enabling infrastructure). The accompanying Business and Regulatory Impact Assessment (BRIA) (Scottish Government, 2022) provided the structure for understanding barriers and delivery risks (e.g., market immaturity, infrastructure needs, investment uncertainty and policy coordination requirements). These informed the way uncertainty is reflected in model dials and scenario ranges rather than treated as fixed outcomes.

The Scottish Government export plan (A Trading Nation: Realising Scotland’s Hydrogen Potential – A Plan for Exports) (Scottish Government, 2024) was then used to add an explicit export-system perspective. This source helped structure how the model considers Scotland’s role not only as a domestic hydrogen producer, but as a future exporter into UK and European markets. It highlighted practical enablers and constraints around export market development. These include demand assurance, certification, transport routes, ports and terminals, storage, and international coordination. These considerations were important for how infrastructure requirements and timing assumptions are framed in the model, particularly where export demand competes with or complements domestic demand growth.

A second group of sources was used to understand the UK-wide policy and commercial framework, which materially affects whether Scottish projects can progress. The UK Government’s Low Carbon Hydrogen Production Business Model (DESNZ, 2022) and the Low Carbon Hydrogen Agreement (LCHA) (BEIS, 2022) were important for understanding the commercial support architecture (e.g., long-term contractual support and price/reference-price concepts), and therefore for interpreting what kinds of projects may be financeable under different market conditions. The Hydrogen Update to the Market (DESNZ, 2025) was used as a current-state snapshot of UK policy progression and programme delivery (e.g., allocation rounds, project support progress, and updates on transport and storage business model development). This helped avoid designing scenarios around outdated assumptions and provided evidence on the pace at which the UK hydrogen market architecture is maturing.

For the power-system interface, the Hydrogen to Power consultation response (DESNZ, 2024) and the Clean Power 2030 Action Plan (UK Government, 2024) were key to understanding the emerging role of hydrogen in dispatchable, low-carbon flexible generation and system balancing. These sources frame hydrogen-to-power as a strategic, but policy-dependent, demand pathway with relevance for long-duration/seasonal balancing and firm capacity provision rather than bulk generation. This was important for defining when hydrogen-to-power demand should appear in scenarios, and how strongly it should be linked to wider electricity-system conditions and policy support. The hydrogen blending consultation document (DESNZ, 2025) was also used, but mainly as a transitional/uncertain demand pathway: it is reflected in the model as an enabler for earlier uptake rather than a core long-term demand assumption.

A third group of sources supported the representation of infrastructure and delivery pathways. The Net Zero Technology Centre (NZTC) Hydrogen Backbone Link (NZTC, 2024) report was used for understanding the strategic case and practical considerations for linking Scotland to European demand centres, including route/infrastructure development thinking and export system integration. The Joint Research Centre (JRC) assessment of hydrogen delivery options (JRC, 2021) and the academic journal article ‘An analysis of the bulk transport of green hydrogen at sea: Comparison between submarine pipeline and compressed and liquefied transport by ship’ (d’Amore-Domenech, R. et al., 2023) provided broader techno-economic context on transport vectors (e.g., pipelines vs shipping and derivative pathways) and how technology choice depends on distance, scale and delivery context. These sources did not directly set final technical parameters, but they strongly informed the infrastructure options represented in the model, i.e., trailers, pipelines and ships.

Finally, the IEA Global Hydrogen Review 2025 (IEA, 2025) and World Energy Outlook 2025 (IEA, 2025) were used as macro-level context sources. The Global Hydrogen Review was especially valuable for understanding the gap between announced project pipelines and projects reaching firm investment stages. It also helped with understanding the continued importance of established demand sectors and the central role of policy support, offtake certainty and infrastructure in unlocking deployment. The World Energy Outlook provided broader power-system and energy-security context (e.g., rising electrification, flexibility needs, grid and resilience constraints), which is relevant for interpreting hydrogen’s role in a future Scottish energy system and for ensuring the model reflects wider system interactions, rather than hydrogen in isolation.

Overall, the literature review provided the evidence base to define a policy-aware, infrastructure-aware and market-aware model structure for Scotland. It informed which dials were necessary in the model (e.g., policy support strength, export ambition, sector uptake, infrastructure rollout timing), the plausible ranges for projected system development, and the main risks and dependencies that should be reflected in scenario interpretation rather than hidden as fixed assumptions.

The representation of Scotland’s current energy system was primarily based on public data from the Scottish Energy Statistics Hub (Scottish Government, 2026), which was used to compile historical datasets on energy, heat and electricity demand. This source also informed the sectoral breakdown of fuel consumption, geographic patterns of consumption, and historical greenhouse gas emissions by type. These datasets were used to establish the baseline system conditions against which hydrogen deployment pathways were assessed.

Variable renewable energy source (VRES) capacity factors were derived from historical installed capacity and actual generation data. This enabled the model to reflect observed system performance and variability, rather than relying solely on generic capacity factor assumptions.

Most of the technical parameters used in the model were drawn from Ramboll’s internal expert knowledge, project experience, and proprietary databases developed across previous hydrogen and energy system studies. These parameters include electrolyser (ELY) efficiencies, low heating values, hydrogen storage characteristics, pipeline specifications, hydrogen tube trailer and shipping assumptions, and conversion/logistics values for hydrogen derivatives such as ammonia, e-methanol and sustainable aviation fuel (SAF). Using these internal sources ensures consistency across technologies and alignment with current engineering practice used in project development.

Scenarios

The research developed two scenarios for hydrogen in Scotland, each of which has a different underlying logic while maintaining an IEA related scope. The two following paragraphs describe the scenarios and their storyline. The scenarios are analysed using the model and results are shown in section 5.

Scenario 1 – “Pragmatic scale-up” (STEPS-aligned; hydrogen grows, but demand remains the binding constraint)

Scotland develops hydrogen in a world that broadly follows the IEA Stated Policies Scenario (STEPS) (IEA, 2025). Governments expand policies beyond what is already enacted. Barriers to new technologies are lower than in a “current policies” world, but aspirational targets are not fully met and new fuels often struggle without continued support. In this context, hydrogen activity expands, but the rate limiter is bankable demand rather than project announcements or supply potential.

Globally, hydrogen demand is still dominated by established uses (refining, chemicals such as ammonia/methanol), while new applications remain small. The IEA notes that new applications are <1% of total hydrogen demand and are heavily concentrated in a limited number of test projects. Scotland therefore prioritises near-term, contractable demand pools (industrial users, refining/chemicals, public procurement) and uses Hydrogen Allocation Rounds / business model instruments to close the cost gap. This reflects the IEA conclusion that stable, predictable demand is a key lever and that firm offtake remains limited, relative to announced project potential.

On supply, Scotland’s comparative advantage is access to low-emissions electricity. However, the “pragmatic” scenario also gives blue hydrogen a meaningful early role. This is because the cost gap for electrolytic hydrogen remains challenging and CCUS-based routes can be competitive in some regions. Accordingly, Acorn CCS progress and an acceptability window for blue hydrogen materially affect the build-out trajectory.

Hydrogen for power system firming/peaking is limited to demonstrations and niche resilience needs, consistent with STEPS’ observation that the dynamism of electricity isn’t automatically matched by strong uptake of low-emissions fuels without policy support.

Exports are a medium-term option, not the backbone: the IEA highlights that hydrogen trade remains limited today and that export-oriented projects often lack off-takers and face infrastructure constraints. Scotland therefore develops export capability cautiously, with realistic delays and selective market focus (UK first; EU later).

Scenario 2 – “Industry breakthrough” (NZE-leaning; hydrogen becomes a strategic pillar for shipping, aviation and industry)

Scotland accelerates hydrogen development in a world moving closer to an IEA Net Zero Emissions by 2050 (NZE)-type pathway (IEA, 2025). In this pathway low-emissions molecules play a larger role because electrification cannot fully decarbonise all end-uses. The use of low-emissions hydrogen and hydrogen-based fuels rise sharply (including high shares in aviation and shipping). Hydrogen-based fuels become a major decarbonisation vector for parts of transport and industry.

In scenario 2, Scotland’s policy framework is designed around the IEA’s central diagnosis that demand certainty is the key lever for investment. Support mechanisms are strengthened, long-term revenue stabilisation expands, and government orchestrates large, credible demand pools (industry clusters, ports, aviation fuel supply chains). The UK and Europe become lead markets for synthetic fuels through SAF mandates that include explicit hydrogen-based sub-targets, creating meaningful e-fuel volumes by 2030 and beyond.

Shipping demand accelerates because the regulatory environment tightens. The IEA describes how the IMO Net-Zero Framework (fuel intensity standard + GHG pricing) can incentivise low-emissions fuels, and that ports and bunkering infrastructure become pivotal early-mover nodes. Scotland leans into this by positioning key Scottish ports as hydrogen-derivatives hubs (ammonia/methanol). This aligns with the IEA’s finding that hydrogen-based fuel handling is concentrated in a limited set of ports and that infrastructure readiness can unlock early offtake.

Export development becomes a cornerstone in hydrogen sector ramp-up. While the IEA cautions that trade is limited today and export projects often lack off-takers, it also shows that trade-oriented project announcements are large and that ammonia/methanol can scale with the right contracts and terminals. Scotland therefore uses aggressive offtake aggregation and export infrastructure build-out, targeting both UK balancing and EU demand growth.

On supply, cheap renewable electricity is fully mobilised (electrolysis at scale). Blue hydrogen plays a time-limited bridging role, contingent on CCS delivery and emissions standards. This reflects the IEA view that multiple production routes can compete depending on costs and policy.

5. Hydrogen deployment model

The deployment model is at the core of this research. This section provides a summary of the purpose, the workflow and the outputs it delivers. The Annex contains a step-by-step description of the model in the form of a user guide. Detailed technical sources are marked within the model.

Purpose and design philosophy

The low-carbon hydrogen deployment model is a scenario-based analytical tool built to estimate hydrogen demand across Scotland’s key sectors through to 2050. It estimates the supply-side infrastructure required to meet that demand. The model was developed to accompany existing qualitative analysis on Scotland’s hydrogen potential. It provides a quantitative, user-friendly framework capable of translating different policy, economic, and technological assumptions into concrete, sector-level hydrogen demand projections and infrastructure requirements.

The model allows users to configure a range of external conditions, energy prices, policy ambition, infrastructure readiness, and others, and observe how sensitive hydrogen deployment is to each of those assumptions. Throughout development, the model structure and its underlying assumptions were refined in close collaboration with the project steering committee. This ensured that the tool was tailored to the specific needs of Scottish policymakers and grounded in the most relevant available evidence. This makes the model serve not just as a forecasting tool, but as a structured framework for stress-testing assumptions, identifying critical dependencies, and supporting evidence-based decision-making.

The model deliberately does not take account of deployment costs to reflect the aim of defining transition possibilities and infrastructure needs. Outputs should be seen to represent transition potential, under certain policy assumptions. The key to the outputs lies in the identification of hydrogen uptake potential per sector, given certain policies.

The model is designed primarily as a scenario exploration and policy testing tool rather than a predictive forecasting model. Its purpose is to assess how different combinations of policy, market, infrastructure and economic conditions may influence hydrogen deployment in Scotland. The outputs should therefore be interpreted as conditional scenarios based on the assumptions and calibration choices embedded within the model, rather than forecasts of future deployment

Model workflow

The model is organized into four interconnected modules, covering demand, production, infrastructure, and exports. Each module captures a distinct dimension of the hydrogen system, see Figure 1. These modules are linked through a common set of user-adjustable input parameters, referred to as dials. These represent the external conditions that determine whether hydrogen becomes competitive in a given sector. The dials allow for specifying Scottish factors such as electricity and gas prices, policy and funding strength, and CCUS infrastructure availability. They also address international parameters governing Scotland’s potential to supply hydrogen to the rest of the UK and the EU.

Electricity price inputs, including user-defined values for 2035, 2040, and 2050, and a score for the broader power procurement and grid environment, form the primary driver of competitiveness across the model. Alongside these, sector-specific policy levers capture the strength of support for hydrogen in individual end-use areas, including heat adoption, power generation, shipping, sustainable aviation fuel, and green ammonia production. A further set of infrastructure dials governs the availability of enabling conditions: the status of carbon capture and storage infrastructure, whether hydrogen production is assumed to be centralised or distributed across Scotland, the availability of export routes to the rest of the UK and the EU, and any assumed delays to deployment. Finally, three macroeconomic parameters (cost of labour, tax regime business impacts, and overall macroeconomic tendency), are combined with electricity price indicators into a composite Demand Development Score, which describes the growth or contraction of legacy sector energy demands over the modelling period.

Each dial setting is converted into a normalised score. These scores are combined, using literature-calibrated weightings, into a single Competitiveness and Likelihood Indicator (CLI) for each demand sector. The CLI captures, in a single value, how favourable the overall environment is for hydrogen adoption in a given sector under the chosen scenario. Each sector is assigned a specific deployment threshold: the CLI must exceed this threshold before any hydrogen uptake occurs in that sector. The presence of positive sector-specific policy support reduces the threshold, reflecting how targeted policy can unlock deployment in sectors where hydrogen would not otherwise be competitive on its own.

The CLI score is then used to determine deployment scale through sector-appropriate logic. For capital-intensive, binary sectors (such as potential hydrogen-based steel plants), the CLI triggers discrete investment decisions, reflecting the all-or-nothing nature of large industrial commitments. For more incremental sectors such as distilleries or road transport, a logistic S-curve converts the CLI into the fraction of total energy demand that switches to hydrogen. The shape and position of the curve is calibrated to reflect each sector’s technology maturity and typical investment cycle. Separate CLIs are calculated for rUK and EU export markets to capture Scotland’s relative competitiveness as a hydrogen and derivatives exporter in each of those markets.

Once sector-level hydrogen demand is established, the model builds full annual trajectories from 2026 to 2050. Deployment timing is governed by a combination of a sector start year, a construction or transition period, and any assumed delay. Together, these determine when hydrogen first enters service in each sector. Different sector types follow distinct demand calculation logics. Legacy incremental sectors project demand by applying the CLI-derived uptake share to current energy consumption, adjusted for the efficiency difference between existing fuels and hydrogen. Legacy non-incremental sectors shift demand on a plant-by-plant basis as the CLI crosses relevant thresholds. New capital-intensive industries derive demand from the number of plants triggered by the binary CLI logic multiplied by per-plant hydrogen consumption. New incremental export demands are matched against literature-derived estimates of accessible rUK and EU import markets, modulated by infrastructure availability and assumed build-out timelines. For the domestic aviation sector, an additional SAF mandate calculation runs in parallel with the general deployment logic, and the higher of the mandate-required volume and the model’s standard deployment projection is taken as the binding output.

The blue-green production is configured directly through the blue hydrogen acceptability dials. These set the relative construction share of electrolysis versus methane reforming with carbon capture, the maximum permissible share of blue hydrogen in the overall supply mix, and the years within which blue hydrogen is eligible to enter and exit the system. If Project Acorn is set to be cancelled in the infrastructure dials, the blue hydrogen share defaults to zero regardless of other inputs.

The infrastructure module then translates production volumes into physical asset requirements, pipelines, storage, and distribution. It uses spatial heuristics that account for whether production is assumed to be centralised at hydrogen hubs or dispersed across Scotland’s geography to serve distributed loads.

Outputs

The model produces a comprehensive set of time-series and summary outputs intended to directly inform infrastructure planning and policy analysis. On the demand side, these include annual hydrogen consumption by sector and production pathways from 2026 to 2050, alongside export volumes to rUK and EU markets. On the supply side, the model derives the electrolyser capacity and renewable electricity requirements associated with green hydrogen production, the SMR or ATR plant capacity and CO2 storage volumes associated with blue hydrogen. It also derives the transport and distribution infrastructure, pipelines, storage, and haulage fleet, required to connect supply to demand across Scotland’s geography. All outputs are accessible through a visual dashboard that allows scenario assumptions to be configured, and results observed in a clear and comparable way.

6. Results

The model was run under the two scenarios described in Section 5.2, generating annual hydrogen demand trajectories, production profiles, and infrastructure requirements from 2026 to 2050. The two scenarios are designed to bracket a plausible range of futures: Scenario 1, ‘pragmatic scale-up’, reflects a world of constrained but real hydrogen growth, while Scenario 2, ‘industry breakthrough’, represents an accelerated, NZE-aligned pathway in which hydrogen becomes a structural pillar of Scotland’s industrial sectors where reducing greenhouse gas emissions is particularly challenging. Both scenarios include support through aviation and shipping targets, moderate-to-low electricity prices, and pipeline export infrastructure to the rest of the UK and the EU, though the timing, scale, and ambition of these conditions differ between them. A key distinction is the role of blue hydrogen: the less ambitious scenario includes a meaningful share of methane reforming with carbon capture. This reflects the persistent cost gap for electrolysis in a pragmatic world. The more ambitious scenario converges rapidly on near-exclusively green hydrogen production.

An overview of the key results across the two scenarios is shown in Table 1^[1]

Scenario 1 – Pragmatic scale-up

Scenario 1 is configured around a distributed deployment of electrolysers, lower overall macroeconomic growth, higher acceptability of blue hydrogen, and low-to-moderate targets for transport sectors. Export infrastructure, i.e., pipeline connections to both the rest of the UK and the EU, is built out but subject to delay, meaning international flows do not begin until 2038. No hydrogen-based heat decarbonisation is assumed.

Under this configuration, total hydrogen demand in Scotland reaches 40.2 TWh by 2050, supported by 11 GW of installed green electrolyser capacity and 135 MW of blue hydrogen production. Demand is modest through the late 2020s, then accelerates between 2030 and 2040 as derivatives export production scales up. A domestic ammonia-for-fertiliser plant is triggered by policies, contributing approximately 2.6 TWh of annual demand. By 2035, cumulative annual demand reaches approximately 9.8 TWh, before growing more gradually to the 2050 endpoint. See Figure 2 for an overview of demand for Scottish hydrogen.

Exports account for a large share of Scenario 1 demand. Pure hydrogen exports to the rest of the UK and the EU reach approximately 18.7 TWh per year by 2050, while hydrogen derivatives exports, primarily ammonia and e-fuels for shipping and aviation markets, contribute a further 7.2 TWh. While the export pipeline infrastructure is eventually built in this scenario, the assumed delays mean that pure hydrogen exports do not commence until 2040 and derivatives exports only begin to ramp meaningfully from 2033 onward.

Scotland’s domestic hydrogen demand reaches approximately 11.4 TWh by 2050. Shipping is the single largest end-use sector, contributing around 4.6 TWh as Scotland’s ports and short-sea routes transition toward ammonia and methanol-based fuels. Aviation, incorporating both general sector uptake and volumes driven by the UK SAF mandate, accounts for approximately 1.5 TWh. Industrial demand is anchored by the chemical industry (approximately 1.8 TWh). The energy sector, hydrogen for power system firming and peaking, demands approximately 1 TWh, with electricity sector end-use adding a further 0.4 TWh. Road transport does not see an uptake, while distilleries and the mineral industry together account for under 0.4 TWh. Heating, light vehicle transport, rail, and paper and wood production do not register material hydrogen demand under this scenario. This is either because the CLI does not exceed sector thresholds or because the assumed policy and infrastructure conditions do not make hydrogen the least-cost decarbonisation option in these areas. Figure 3 shows domestic hydrogen demand across all sectors.

Scenario 2 – Industry breakthrough

Scenario 2 is configured around a centralised deployment of electrolysers with lower reliance on distributed small-scale infrastructure. It has high transport sector targets for both shipping and aviation, low acceptability of blue hydrogen, and more favourable electricity prices. Export infrastructure to the rest of the UK is available on time, while the EU export route is subject to delay. As in Scenario 1, no hydrogen-based heat decarbonisation is assumed. These settings reflect an accelerated policy environment in which strong regulatory support, SAF mandates with hydrogen sub-targets, tightening IMO shipping regulations, and orchestrated industrial demand clusters, enables a step-change in Scotland’s hydrogen deployment, consistent with an NZE-aligned global trajectory.

Under this configuration, total hydrogen demand reaches 70.3 TWh by 2050, supported by an almost entirely green production system totalling approximately 19.5 GW (19.4 GW of installed green electrolyser capacity and 0.12 GW of blue hydrogen). The deployment trajectory is steeper and earlier than in Scenario 1. By 2035, annual demand has already reached approximately 30.7 TWh, driven by the more rapid mobilisation of export infrastructure and the higher transport sector targets. Growth continues, albeit at a more modest pace, through to 2050. The near-complete absence of blue hydrogen in this scenario reflects both the low acceptability dial setting and the expectation that scale-up of green electrolysis, combined with stronger policy support, is sufficient to meet demand from an early stage. See Figure 4 for an overview of demand for Scottish hydrogen.

As in Scenario 1, exports dominate overall demand also in Scenario 2, with derivatives and pure hydrogen exports together accounting for the majority of the 42 TWh total. The earlier availability of the UK export pipeline (on time in this scenario) allows hydrogen trade with the rest of the UK to commence sooner. This strengthens the export revenue case and accelerates the investment rationale for large-scale electrolyser deployment. Domestic demand is driven by a higher-ambition transport sector, with shipping and aviation contributing materially more than in Scenario 1 due to the high regulatory and policy support settings. Industrial hydrogen demand, i.e., steel, chemicals, and associated sectors, follows broadly comparable trajectories to Scenario 1. This is because these sectors are anchored by binary investment decisions that are triggered once the CLI crosses the relevant threshold in both cases. The centralised infrastructure model in Scenario 2 concentrates electrolyser and storage capacity at hubs. This results in a smaller number of decentralised small-scale asset requirements compared to Scenario 1, but requires a more developed inner-Scottish pipeline and transmission system.

Comparison with previous studies

Scenario 1’s projected 40.3 TWh of demand is higher than many more conservative studies. It is well above the FES Falling Behind scenario (~2.9 TWh in 2050), FES Electric Engagement (~10.4 TWh), and the SPICe Spotlight assessment (~14.9 TWh). However, it is notably below the SHA Scenario A H2 Economy result (~65 TWh) and considerably below the Scottish Government’s headline trajectory derived from the Hydrogen Policy Statement, Hydrogen Action Plan, and Trading Nation export plan (which implies approximately 126 TWh by 2050). The result most closely resembles the FES Hydrogen Evolution scenario (~34.5 TWh), but is slightly higher due to the large export volumes that become available once infrastructure is in place. See Figure 6 for a comparison of Scenario 1 with related studies and Figure 7 for a comparison of Scenario 2.

Scenario 2, at approximately 70.3 TWh, comes much closer to the SHA Scenario A H2 Economy benchmark (~65 TWh). It represents the upper end of what a policy-supported, demand-led deployment model credibly projects without assuming full alignment with the most optimistic supply-push scenarios. Like Scenario 1, it remains below the 126 TWh implied by Scottish Government headline targets and the SHA Scenario B Green Export pathway. This underscores the fact that achieving those ambitions would require not only the strong policy and infrastructure conditions embedded in Scenario 2, but also additional demand creation, export market development, and a pace of scale-up that the model’s current calibration does not support. Both scenarios are, however, consistent with the IEA’s assessment that Scotland-scale producers in a STEPS-to-NZE world can expect to occupy the mid-range of the hydrogen deployment spectrum. This means they can be significant contributors to a decarbonising energy system, but constrained by the pace at which global demand for hydrogen and its derivatives actually materialises.

Conclusions

At the core of this research is the development of a hydrogen deployment model. The two scenarios generated by the Scotland hydrogen deployment model represent a test to model functionality as well as an outlook on future system development under IEA related assumptions. The modelling suggests substantial hydrogen deployment in Scotland under a range of future policy and market conditions. Across both scenarios, exports account for the majority of hydrogen demand by 2050, highlighting the importance of Scotland’s ability to access UK and European markets. The results also indicate that electricity prices and the availability of export infrastructure are the most important determinants of deployment, with both factors strongly influencing the scale and pace of hydrogen uptake

Scenario-related considerations

The scenarios show a moderate and a more ambitious outlook for Scotland’s hydrogen sector, spanning a range from approximately 40.2 TWh to 70.3 TWh of total hydrogen demand in 2050. Both scenarios show a period of steep growth between approximately 2030 and 2040 (as export infrastructure, derivatives production, and key industrial investments come online), followed by slower growth through the 2040s. Both scenarios estimate a level of demand in 2050 that is below what can be seen in other studies and projections.

The model’s outputs are most sensitive to two parameters: electricity prices and the availability of export infrastructure. Electricity prices are the primary determinant of the business case for green hydrogen production, directly governing both the competitiveness of electrolysis relative to fossil alternatives and the Competitiveness and Likelihood Indicator scores that drive uptake across most demand sectors. This sensitivity highlights that cheap, reliable access to renewable electricity is the foundational condition for green hydrogen business cases: electricity costs make up the largest component of electrolytic hydrogen production costs.

Export infrastructure availability acts as a hard structural boundary: if pipeline connections to the rest of the UK and the EU are not in place, international hydrogen demand, which accounts for the majority of total modelled deployment in both scenarios, cannot be incorporated regardless of how favourable other conditions are. The findings therefore reinforce the importance of timely infrastructure development alongside continued efforts to secure competitive renewable electricity.

Model development – lessons and next steps

We developed the model to describe deployment of hydrogen and hydrogen related infrastructure in Scotland. It serves as a tool for generating and testing alternative deployment scenarios. It links policy choices and market conditions to hydrogen demand and associated infrastructure requirements. The underlying logic is anchored in determining the demand for hydrogen across different sectors based on the policy landscape and support mechanisms available. Demand for hydrogen translates into the need for hydrogen infrastructure.

The main challenge of implementing policy-driven hydrogen uptake lies in meaningfully combining demand and supply-side support policies for deployment modelling. The approach we took was to work from demand estimation, based on policies. This takes limited account of supply-side-driven uptake of hydrogen. The main aim of this project was to create a user-friendly modelling tool. Within the time and resource available, the capacity for simultaneous modelling of both supply and demand side factors was limited.

The following model refinements may produce more detailed outputs:

• Electricity prices: More detailed electricity price series could improve representation of hydrogen competitiveness.
  
• Demand data: Improved sector-level demand data and bottom-up estimates of current energy use could enhance the quality of outputs .
  
• Hydrogen adoption pathways: Better evidence on technology readiness and sector-specific adoption pathways could refine uptake assumptions.
  
• Technology maturity and adoption: More explicit cost-based assessment of competition between technologies may improve representation of future trade-offs between blue and green hydrogen, alternative transport modes and storage options.
  

References

International Energy Agency (IEA) (2025) World Energy Outlook 2025. Paris: IEA.

Scottish Government (2024) A Trading Nation: Realising Scotland’s Hydrogen Potential – A Plan for Exports. Edinburgh: Scottish Government.

d’Amore-Domenech, R. et al. (2023) ‘An analysis of the bulk transport of green hydrogen at sea: Comparison between submarine pipeline and compressed and liquefied transport by ship’, Energy, 263, 125905.

Net Zero Technology Centre (NZTC) (2024) Hydrogen Backbone Link: Connecting Scotland to Europe – Report 3. Aberdeen: Net Zero Technology Centre.

Department for Energy Security and Net Zero (DESNZ) (2023) Low Carbon Hydrogen Certification Scheme: Consultation Response. London: DESNZ.

Department for Business, Energy & Industrial Strategy (BEIS) (2022) Low Carbon Hydrogen Production Business Model: Heads of Terms. London: BEIS.

Department for Energy Security and Net Zero (DESNZ) (2025) Low Carbon Hydrogen Agreement (LCHA): HAR1 Key Terms Summary and Explanatory Notes. London: DESNZ.

European Commission, Joint Research Centre (JRC) (2021) Assessment of Hydrogen Delivery Options. Luxembourg: Publications Office of the European Union.

Department for Energy Security and Net Zero (DESNZ) (2025) Hydrogen Update to the Market (July 2025). London: DESNZ.

European Commission, Joint Research Centre (JRC) (2021) Assessment of Hydrogen Delivery Options. Luxembourg: Publications Office of the European Union.

Department for Energy Security and Net Zero (DESNZ) (2025) Hydrogen Update to the Market (July 2025). London: DESNZ.

Department for Energy Security and Net Zero (DESNZ) (2024) Hydrogen to Power: Consultation Response. London: DESNZ.

Department for Energy Security and Net Zero (DESNZ) (2025) Hydrogen Blending into the GB Gas Transmission Network: Consultation Document. London: DESNZ.

Scottish Government (2022) Hydrogen Action Plan: Business and Regulatory Impact Assessment. Edinburgh: Scottish Government.

Scottish Government (2022) Scottish Hydrogen Action Plan. Edinburgh: Scottish Government.

International Energy Agency (IEA) (2025) Global Hydrogen Review 2025. Paris: IEA.

Department for Energy Security and Net Zero (DESNZ) (2024) Clean Power 2030 Action Plan (Main Report). London: DESNZ.

Scottish Government (n.d.) Scottish Energy Statistics Hub. Edinburgh: Scottish Government.

European Commission (2026) REPowerEU. European Commission.

How to cite this publication:

Mouelhi, B., Martin Nieto, C., Lüth, A., Raheli, E., Bush, R. (2026) ‘A Low Carbon Hydrogen Deployment Model for Scotland’, ClimateXChange. DOI https://doi.org/10.7488/era/7184

© The University of Edinburgh, 2026.
Prepared by Ramboll on behalf of ClimateXChange, The University of Edinburgh. All rights reserved.

While every effort is made to ensure the information in this report is accurate as at the date of the report, no legal responsibility is accepted for any errors, omissions or misleading statements. The views expressed represent those of the author(s), and do not necessarily represent those of the host institutions or funders.

This work was supported by the Rural and Environment Science and Analytical Services Division of the Scottish Government (CoE – CXC).

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1. Throughout section 5, hydrogen demand is reported in four categories: (a) domestic demand is hydrogen consumed within Scotland across industrial, transport and energy sectors; (b) pure hydrogen exports is hydrogen exported directly to the rest of the UK or the EU; (c) derivative export demand is hydrogen used in Scotland to produce export products such as ammonia, methanol and SAF; (d) total hydrogen demand is the sum of domestic demand, export demand and hydrogen used for derivative production.
   Unless otherwise stated, references to total hydrogen demand include all four components. ↑
   

   
   

Hydrogen derivatives and products (HDPs) are made by combining hydrogen with other elements. These processes make products that can be more easily used, transported or stored than pure Hydrogen.

With Scotland’s ambitious plans to increase low-carbon hydrogen production, HDPs are expected to play an important role in reducing emissions from sectors such as aviation, shipping and road transport. They could also create new export opportunities for Scotland.

This report focuses on ammonia, e-methanol, synthetic aviation fuel (SAF) and other e-fuels (made using hydrogen and captured carbon dioxide). It assesses whether current Scottish, UK, European and international regulations are suitable for supporting the production, storage, transport and use of these fuels. It identifies where they provide a strong foundation and where changes could help the sector grow.

Key findings

• Our study found strong foundations for regulations related to: planning; technology; and health, safety and environmental (HS&E) standards. These include Scotland’s planning and environmental systems, the UK’s Control of Major Accident Hazards (COMAH) framework, and international shipping standards covering hydrogen-derived products.
• Market regulations for hydrogen-derived products are the least fit-for-purpose. A lack of clarity and consistency mean they do not increase confidence in long-term production, and they provide uneven support across products. The key limitations identified are:
  • Support is heavily weighted towards sustainable aviation fuel (SAF). Comparable incentives are not available for ammonia, e-methanol or sustainable marine fuels.
  • Differences between UK and EU rules for renewable fuels and SAF could reduce Scotland’s export competitiveness.
  • Uncertainty in the UK Emissions Trading Scheme (ETS) creates further risk. Power-to-Liquid SAF (e-SAF) is not currently zero-rated, and it is unclear whether the ETS will extend to shipping, reducing confidence in future demand.

Recommendations

• Regulations related to consenting and health, safety and environmental standards (HS&E) should be monitored to ensure they remain fit-for-purpose as the HDP markets and technologies develop.
• Support International Maritime Organization (IMO) proposals to reduce emissions, encouraging future demand for hydrogen-derived marine fuels.
• Most regulations were not designed to support hydrogen-derived products. New support mechanisms, similar to those already available for green hydrogen, could help grow the sector.
• Address gaps and inconsistencies in market rules, including better alignment between UK and EU requirements to support Scottish exports.
• Include e-fuels, including e-SAF, in the UK Emissions Trading Scheme (ETS) and introduce dedicated support for ammonia and e-methanol, similar to existing support for sustainable aviation fuel (SAF).

March 2026

DOI: https://doi.org/10.7488/era/7017

Executive summary

Aims

Scotland has set ambitious climate and hydrogen policies, including an ambition of 5 gigawatts (GW) of low‑carbon hydrogen production by 2030 rising to 25 GW by 2045. Hydrogen derivatives and associated products are expected to play a key role in enabling domestic decarbonisation. They are also expected to help position Scotland as an exporter to meet growing European demand.

Hydrogen derivatives are produced by combining hydrogen with other elements that can be more easily transported and stored. They may then be converted back into hydrogen or used directly as fuels or feedstocks. Where no further processing or conversion occurs before use, the term hydrogen product is used.

This study assesses whether the current regulatory landscape is fit‑for‑purpose to support the growth of hydrogen derivatives and products: ammonia, e‑methanol as well as synthetic aviation fuel (SAF) and wider e-fuels (fuels produced by combining hydrogen with carbon dioxide via electrolysis). Throughout this study these are referred to as hydrogen derivatives and products (HDPs).

The objective is to identify limitations and gaps within the current regulations and propose associated interventions. Drawing on an extensive regulatory review, stakeholder engagement and a criteria-based assessment, this study seeks to answer the following research questions.

1. What is the regulatory landscape for ammonia, e‑methanol and SAF in Scotland?
2. To what extent is the current regulatory regime fit‑for‑purpose to enable Scottish hydrogen derivative production, storage, transport and end‑use?
3. What interventions are needed to create a coherent, safe and effective regulatory environment that accelerates HDPs across the value chain?

The assessment covers fuel types derived from green hydrogen and captured CO₂, and excludes bio‑derived fuels (e.g., bioethanol or biodiesel) and hydrogen production itself. The areas of hydrogen derivative value chain covered include: production in Scotland; storage; transport and use. Our assessment groups regulations by jurisdictions (both domestic and international) and impact area. Impact areas include: consenting and planning; route to market; technical standards and health, safety and environment standards (HS&E). This work follows previous ClimateXChange studies looking at HDP supply chain capabilities (Ella Yip, 2025) and the demand for HDPs (Szebasztian Csernik-Tihn, 2024).

Findings

Our study found strong existing foundations across all jurisdictions for consenting, technology standardisation and HS&E related regulations. These included existing planning, consent and environmental authorisations in Scotland, UK HSE legislations such as COMAH as well as the inclusion of HDPs in international standards under the International Maritime Organisation (IMO).

Route to market regulations, which cover hydrogen derivative related definitions, eligibility requirements and dedicated targets or mandates, were deemed least fit-for-purpose across all jurisdictions. They currently lack the clarity and cross-jurisdictional consistency to fully de-risk long-term production and market demand to maximise opportunities. They further do not provide incentives across all derivatives equally. The key limitations we identified included:

• Uneven support across derivatives
  The UK policy landscape is currently skewed toward SAF, represented by the dedicated SAF mandate and revenue support mechanism. No equivalent commercial incentives exist for ammonia or e‑methanol. There is no mandate or incentive for the production of sustainable HDP maritime fuels.
• Misalignment between UK and EU regulatory definitions
  Definitions and requirements for Renewable Fuels of Non-Biological Origin (RFNBOs) and SAF differ, particularly around greenhouse gas (GHG) emission thresholds, and the proximity of renewable electricity sources. Scotland’s export competitiveness into the EU may be limited if producers comply only with UK requirements.
• Uncertainty in the UK Emissions Trading Scheme (ETS)
  Power to Liquid SAF (PtL or e-SAF) – produced specifically using CO₂ and green hydrogen – is currently not zero-rated within the UK ETS, while the future expansion of the UK ETS to cover maritime sectors remains uncertain. This creates a further commercial risk for producers in terms of more limited offtake potential.

Recommendations

• Consenting and HS&E related regulations should be monitored to ensure they remain fit-for-purpose as the hydrogen derivative market expands and technology develops.
• Regarding specific technical standards and associated routes to market, we recommend supporting the progression of the IMO GHG reduction proposals for marine vessels. This encourages a further future offtake market.
  The majority of assessed regulations are not explicitly designed to promote the hydrogen derivative market. Dedicated support options could be considered, in order to further strengthen the sector. Potential interventions can be taken from adjacent sectors such as (green) hydrogen. For example, the Hydrogen Storage Business Model and Hydrogen Transport Business Model currently does not include hydrogen‑derived fuels (e.g., ammonia, e‑methanol). A dedicated mechanism mirrored on these models could be established for the derivative sector.
• Other proposed interventions focus on addressing regulatory discrepancies and gaps in the route to market impact area. This includes promoting the alignment between UK and EU requirements and definitions for HDPs. The EU market represents a strong opportunity for Scottish production and export potential. Securing compliance with regulatory requirements will be essential.
• We further recommend the inclusion of e-fuels / e-SAF within the UK ETS, aligning e-fuels with biomass-derived options and with the EU ETS approach. We also recommend a dedicated route to market support framework for ammonia and e-methanol. This could mirror the current support dedicated to SAF in the UK, such as specific mandates or revenue support mechanisms. 

We recognise the limits of Scottish Government influence on EU and UK regulations, but our recommendations may usefully inform existing conversations and engagement opportunities to seek improvements in these routes to market.

Glossary & abbreviations

Abbreviations

Glossary of terms and units

Introduction

The production of hydrogen derivatives and products (HDPs) forms an integral part of Scotland’s Hydrogen Action Plan (2022) and 2045 net zero targets. The Scottish Government’s aim is to establish Scotland as a key producer and exporter of hydrogen and hydrogen-derived products. This goal is underpinned by a 5GW low-carbon hydrogen production ambition by 2030, increasing to 25GW by 2045. Scottish export ambitions align with the EU’s goal of importing 10Mt of low-carbon hydrogen from outside of the EU by 2030, a significant part of which is anticipated to be in the form of HDPs.

HDPs are chemicals made by combining hydrogen with other elements so that it becomes easier to store, transport or to use as energy. The main HDPs – ammonia, e-methanol, and sustainable aviation fuel (SAF) – are studied in this report. Only HDPs from green hydrogen were considered, and not those where the hydrogen comes from bio-feedstocks. This means that in the case of SAF, only PtL SAF – also called synthetic aviation fuel or e-SAF – is included.

This study forms part of the Hydrogen Action Plan tasks of ‘building our evidence base’ and ‘identifying market access barriers’ for hydrogen and HDPs (Scottish Government, 2022). In this report, we provide an overview and analysis of the current regulatory landscape for HDPs in Scotland, the wider UK, EU and internationally. We focused on regulations applying to the whole value chain of production, storage, transport, and use. The overarching aim is to identify barriers to developing the Scottish HDPs market. This is important for three reasons: the proximity to 2030 ambitions; the need to create transition opportunities for traditional fossil fuel industries and workforce now; and the anticipated strong competition from other HDPs producers for European import targets. Many relevant route to market regulations sit at UK, EU or international level, limiting direct Scottish Government control over implementation. While the Scottish Government’s overall regulatory influence may be more limited at EU and international level, intervention options can still feed into an aligned Scottish-UK position and overall hydrogen strategy.

The research questions we aim to respond to are:

• What is the regulatory landscape for the core HDPs ammonia, e-methanol, and SAF?
• To what extent is the regulatory landscape fit-for-purpose to enable the growth of the HDPs sector in line with Scottish net zero, just transition and hydrogen ambitions?
• What interventions would be needed to create a coherent, safe, and effective framework that accelerates HDPs across all value chain areas?

To address these questions, we first conducted an extensive literature review of relevant regulations across all four jurisdictional levels. We collated applicable regulations in an extensive database and categorised them against their applicability by fuel type, value chain, and impact area.

The hydrogen derivative fuel types considered are: ammonia, e-methanol, SAF and e-fuel (e.g., e-diesel).

The value chain refers to the activities required to produce, transport, store and use HDPs. Each area has different technical process, risks and regulatory requirements. The value chain areas are: production (Scotland focus), storage, transport and use.

Impact areas refer to aspects that can influence the growth and development of a sector. These are:

• Route to Market – This impact area is used to determine the availability of offtake opportunities and customers for HDPs. Any regulations may affect how easily products can reach the customer. Overall regulatory mandates or targets can impact the size of the market available to the HDP producer, thus affecting the sector’s overall business case. Regulations may also capture market access and funding mechanisms (such as subsidies), providing revenue certainty.
  
• Technology development and standardisation – As technology improves, it enables a sector to do things more efficiently and/or effectively. It can further open up new markets or growth areas. Technology development has to adhere to a standard for quality. Standardisation thus creates certainty and safety for products to work reliably for the users. With international standards, these allow for products and services to be exported globally and thus accelerate global adoption in the sector.

Technical standards referenced in this study focus on standards that serve as the de facto global market‑entry requirements embedded in regulatory acceptance for certain fuels. An example of this are the American Society for Testing and Materials (ASTM) standards, which in the case of SAF, determine eligibility as aviation fuels. ISO and BSI standards, while important technical references, do not in themselves confer regulatory approval and therefore fall outside the study’s focus on regulation.

• Health, safety and environment (HS&E) – A strong HS&E framework demonstrates that a sector operates safely and responsibly which builds public trust and attracts investors. It prevents incidents which could cause shutdowns and project delays to enable a smoother long-term growth of the sector. For developers or operators, a clear, standardised HS&E framework can reduce project development uncertainty.
  
• Consenting – A clear and consistent consenting and planning framework can support effective and efficient project development activities. This reduces the risk of project delays and overall uncertainty for project developers and operators. A lack of clear consenting guidelines or uncertain applicability for HDPs may slow or complicate the approvals process, ultimately affecting investor confidence. This could potentially slow the growth of the sector.

We then assessed each regulation to determine suitability for and potential impact on the Scottish HDPs market, using the following criteria:

• Policy intent: To what extent the policy is designed to support development of the HDPs market
  
• Market impact: How it affects market outcomes in practice with respect to project viability, investment decisions or deployment pathways
  
• Scope and breadth of impact: How much of the market is exposed to the policy’s effects (e.g., one or multiple derivatives or value chains)
  
• Certainty and clarity: How clear, stable and well-understood it is and how much requires interpretation for clarity
  
• Degree of regulatory influence: How easily it can be influenced or changed by Scottish and/or UK Government

An overview of the assessment criteria, scoring approach and weightings is provided in Appendix A. Using the total scores, individual criteria outputs, and associated justifications for each regulation we were able to identify initial gaps, limitations and discrepancies across the regulatory landscape and jurisdictional levels. A stakeholder session was held to validate and refine our initial outputs. These combined outputs then formed the basis of our recommended intervention areas.

To help communicate this complex landscape, we also developed a visual map of all regulations across impact areas and value chain levels. This map is available separate to this report and in Appendix C.

Scope Parameters and Limitations

This study focused solely on regulations regarding the production, storage, transport, and use of HDPs. Only fuel types derived from green hydrogen and a carbon dioxide feedstock were covered, not fuels derived from bio-feedstocks. We also excluded the production of low-carbon hydrogen itself and associated feedstocks such as electricity from renewable energy sources. These topics have already been subject to review and reported on in existing studies^[1]

Regulatory landscape for HDPs

In this section, we capture the relevant regulations for HDPs across each of the jurisdictional levels – Scotland, UK, EU and internationally. Each sub-section focuses on one geography, outlining the regulations assessed, the derivatives and value chain elements to which they apply, and their impact areas. The following sub-sections cover each jurisdictional level:

• Scotland
• UK
• European Union
• International

The overarching policy and sector strategies for each geography are laid out to provide context, and to highlight stated policy intent relating to HDPs.

Our intention in this section is to describe the regulatory landscape for ammonia, e‑methanol and SAF produced in Scotland and transported and consumed either domestically or abroad. Section 5 captures the fit-for-purpose analysis with overall assessment outputs accessible in Appendix B.

Where appropriate, the regulations have been grouped together according to impact areas in each geography. Regulations that showed greater relevance in the scoring assessment and subsequent study recommendations were outlined in additional detail for reference.

A visual regulatory map of jurisdictional levels and impact areas accompanies this report.

Scotland

Policy and sector strategy

Scotland set out an ambition of 5GW of renewable and low-carbon hydrogen production by 2030 and 25GW by 2045, in their Hydrogen Policy Statement (Scottish Government, 2020). One of the Scottish Government’s actions from this Statement was to ensure the regulatory, planning and consenting framework for renewable developments would support the scale-up of hydrogen. Hydrogen is an export ambition and HDPs are included as a form of hydrogen transport vector and commodity. Hydrogen derivative developments are subject to an overarching UK regulatory regime. This is discussed further in Section 4.2.

Scottish climate policy

Scotland’s climate policy framework is underpinned by the Climate Change (Scotland) Act (Scottish Government, 2009). This sets a legally binding target for Scotland to achieve net‑zero greenhouse gas emissions by 2045, five years earlier than the UK-wide target. The Act also requires Ministers to set and meet carbon budgets. These carbon budgets will each cover a series of 5-year periods from 2026 to 2045.

In addition, the Scottish Government published its draft Climate Change Plan 2026–2040 (Scottish Government, 2025) in November 2025. This Plan sets out how Scotland intends to meet its first three carbon budgets covering the period 2026–2040, providing a pathway aligned with independent advice from the Climate Change Committee. The draft Plan is currently undergoing public consultation.

Scotland’s draft Climate Change Plan (Scottish Government, 2025) does not address

deployment targets for HDPs such as ammonia and e-methanol. It does mention the Scottish Government’s plan to consider options for increasing SAF production and its use.

Hydrogen Action Plan

The Hydrogen Action Plan (Scottish Government, 2022) positions hydrogen and its derivatives as essential for decarbonising hard‑to‑abate sectors and supporting a just transition. The Plan outlines actions to develop Scotland’s hydrogen economy, including scaling renewable hydrogen production to support derivative fuels for domestic and export markets. It recognises the need for safe, regulated development of derivatives and highlights their potential role in early export pathways to mainland Europe. Direct actions for HDPs in the Plan are in identifying priority export markets internationally and market access barriers for derivatives.

Hydrogen export plan

Scotland published its first hydrogen sector export plan, A Trading Nation: Realising Scotland’s Hydrogen Potential – A Plan for Exports (Scottish Government, 2024) which sets out Scotland’s ambition to become a major exporter of hydrogen and HDPs to European markets, underpinned by ambitions of 5 GW of production by 2030 and 25 GW by 2045. The plan recognises Europe’s rising demand for renewable hydrogen and hydrogen products and positions Scotland as having the renewable capacity, skills and supply‑chain capability to supply derivative fuels at scale.

Scottish regulatory landscape

Scottish regulations relevant to derivatives primarily address procedures in consenting, planning and permitting of certain activities. A UK regulation on Green Freeports which impacts route to market has been included in this section as it is relevant to Scotland. Table 1 captures the assessed regulations for the development of HDPs in Scotland.

The regulatory landscape is not hydrogen or HDPs specific but is neutral in allowing projects which adhere to the planning framework and regulated activities which require permits to proceed.

• The Environmental Authorisations (Scotland) Amendment Regulations 2025 – which amends the 2018 Regulations to create an Integrated Authorisation Framework (IAF). This framework streamlines the Scottish Environment Protection Agency (SEPA) regulation of waste, water, and industrial activities. These regulations cover activities requiring permits that must be gained separately to planning permission. This streamlined regulation is aimed at enhancing efficiency in the process for hydrogen derivative project developers in Scotland. An overall outcome or evaluation of this aim was not available at the time of writing.
  
• Marine Works (Environmental Impact Assessment) (Scotland) Regulations 2017 – regulations which govern EIAs for Scottish marine developments within the 12-nautical mile boundary. For hydrogen derivative projects, the water usage, waste discharge as well as infrastructure risks will be considered.
  
• Finance Act 2021 with Finance (No. 2) Act 2023 – the 2021 Act (UK Government, 2021) and 2023 amendments (UK Government, 2023) set the UK‑wide legal basis for Freeports, including the tax reliefs and commercial incentives available within designated Freeport tax sites. In Scotland, this framework is applied through the Green Freeports, which focus on net‑zero and just‑transition objectives, including low‑carbon fuels and energy transition projects. This makes it relevant to the hydrogen‑derivatives landscape. For example, the Forth Green Freeport identifies opportunities for alternative fuels alongside offshore wind, shipbuilding, modular manufacturing and creative industries. This emphasis on net‑zero activities provides an additional policy route and potential market access point for HDPs.
  
• Town and Country Planning Act 1997 – the principal consolidating statute that provides the core legal framework for regulating land development, preparing development plans, determining planning applications, and enforcing planning control in Scotland (as significantly amended by later Acts such as the Planning etc. (Scotland) Act 2006 and the Planning (Scotland) Act 2019).

UK

Policy and sector strategy

Strategy and policy on climate, transport decarbonisation, and industrial development all influence direction on HDP production and use. The most relevant UK policies and strategies are outlined below focussing on their relevance to HDPs and the scope of this project.

Climate policy

UK Government is obliged to deliver net zero emissions for the UK by 2050 by the Climate Change Act (UK Government, 2008). Legally binding carbon budgets have been set covering the period out to 2037, and the seventh carbon budget (covering 2038 to 2042) needs to be set by June this year. Additionally, the UK Government has ratified the Paris Agreement.

The Carbon Budget and Growth Delivery Plan (UK Government, 2025) lays out how the Government intends to meet its statutory carbon budgets. This focusses on the period to 2037. HDPs are listed directly as achieving emissions reduction in the following areas:

• Aviation (SAF)
• Shipping (low carbon fuels including ammonia and methanol)
• Road Transport (low carbon fuels including ammonia and methanol)

Deployment assumptions are listed for each of these sectors, but no breakdown is given. Therefore, there are no clearly stated deployment targets for the HDPs that are in the scope of this report.

Maritime Decarbonisation Strategy

The Maritime Decarbonisation Strategy (UK Government, 2025) sets out GHG emissions targets for the maritime sector. (30% reduction by 2030, 80% by 2040, 100% by 2050 relative to 2008 levels). This sets out guiding principles that include a co-ordinated approach to regulation with international bodies such as IMO. The document is clear that there are significant roles for ammonia and methanol in decarbonising the maritime sector. The strategy is focussed on achieving decarbonisation and does not include any targets for or give any direction on the need for domestic UK production of these fuels.

Jet Zero Strategy

The Jet Zero Strategy (UK Government, 2022) recognises that SAF is required to reduce emissions from the aviation sector and included the launch of a SAF mandate as a key objective. Relating to production, a KPI for five commercial scale SAF plants to be under construction was set. PtL SAF is not explicitly mentioned, and the strategy only includes general statements on funding for first of a kind commercial and demonstration advanced fuels plants.

Decarbonising transport

The Decarbonising Transport Strategy (UK Government, 2021) includes the UK Government’s strategy for decarbonising road transport. Electrification, biofuels and hydrogen are included as mechanisms to reduce emissions. This strategy introduced plans to phase out internal combustion engine vehicles in the UK, and these plans have been supported by subsequent governments. That means that while there is support for low carbon drop in fuels as an interim solution (such a biofuels), in the long term this type of fuel will be phased out in the road transport sector. There is no current strategy or policy that supports the use of HDPs in this sector.

Industrial strategy

The UK’s Modern Industrial Strategy (UK Government, 2025) has identified Clean Energy Industries as one of eight strategic sectors. The Clean Energy Industries Sector Plan (UK Government, 2025) includes hydrogen but does not specifically mention HDPs.

Hydrogen Strategy

The UK’s Hydrogen Strategy (UK Government, 2021) sets out a framework for scaling hydrogen production, transport, storage, and use, and set an ambition of 5 GW low carbon hydrogen production by 2030, later doubled to 10GW in the British Energy Security Strategy. There is no mention of HDPs in the Hydrogen Strategy. It does establish policy direction on hydrogen standards and business models that indirectly impact the derivative markets.

An update to the Hydrogen Strategy was due in late 2025 but has not been published at the time of writing this report.

UK regulatory landscape

HDPs are regulated through a combination of industrial safety legislation (e.g., COMAH), environmental consenting, and sector‑specific regimes (e.g., shipping, aviation, and industrial chemicals). As such there are multiple stakeholders split across these areas, including Department for Energy Security and Net Zero (DESNZ), Environment Agency, Health and Safety Executive, and Department of Transport. This results in a fragmented regulatory landscape which limits the strategic direction, market impact and regulation clarity for new projects.

Route to market

The considered route to market regulations within the UK are shown in the table below, highlighting which hydrogen derivative(s) they are applicable to and at what point in the value chain.

Many of these regulations do not directly promote HDPs and are driven as a result of decarbonisation targets. Regardless, they have an effect on derivatives. Regulations that will have a market impact on hydrogen derivative products are:

• Energy Act 2023 – provides the statutory framework to implement key elements of UK hydrogen policy. For HDPs, the Act helps enable investment by clarifying market arrangements and government intervention powers. The Act provides the framework for setting up business models and funding structures such as revenue support (e.g., SAF Revenue Support Mechanism, covered further below).
  
• UK Emissions Trading Scheme (UK ETS) – sets a carbon price on emissions only from the power generation, industry and aviation sectors, improving the relative competitiveness of low‑carbon HDPs versus fossil alternatives. This is being reviewed for expansion to maritime sector in 2026 and waste incineration in 2028. At present, PtL SAF (e-SAF) does not receive zero-rated status. Zero‑rated fuels are assumed to have zero carbon emissions when used, a designation that applies only to biomass‑based SAF.
  
• Renewable Transport Fuel Obligation (RTFO) – represents the central policy driver for hydrogen‑derived fuels in the relevant transport sector. This includes road vehicles and non-road transports such as non-road mobile machinery (NRMM) and the maritime sector, if the fuel used is a renewable fuel of non-biological origin (RFNBO). It creates demand for eligible RFNBOs through tradable certificates. An eligible RFNBO is required to
  • Achieve a 65% GHG emission saving over the whole lifecycle relative to the fossil fuels fuel baseline of 94 gCO2eq/
  • demonstrate that the renewable electricity or heat used to produce the RFNBO satisfies regionalisation rules and additionality rules. The regionalisation rule includes demonstrating that the electricity comes from the same region and electricity market where production is located. The additionality rule requires the electricity used to make RFNBO is additional, meaning produced from new, upgraded, and recommissioned production, and not diverted from existing renewable power.

Note this RFNBO definition differs from the EU definition and is further discussed in Section 5.1.1.

• RTFO and Sustainable Aviation Fuel (SAF) Mandate Technical Guidance – provides the guidance on technical requirements which are largely consistent between the RTFO and SAF Mandate, covering classification, carbon and sustainability criteria, GHG calculations and evidence requirements. This guides suppliers and allows RFTO and SAF fuels to be consistent across the UK:
  • sets sustainability rules to qualify for certificates with GHG emission savings relative to fossil fuels for SAF having to be equal or above 40%, and for RFNBOs to be equal or above 65%, respectively
  • provide evidence requirements, which include documentation for eligible fuel feedstock, process emissions, evidence that fuel can be tracked from source to final delivery and audits within the supply chain
• UK Carbon Border Adjustment Mechanism (CBAM) – legislation to prevent cheaper carbon intensive products being imported into the UK. Importers are charged a fee based on the carbon emissions from goods production. This will be introduced from 1 January 2027 and mainly impacts green ammonia imports (as fertilisers are included), making it more competitive. Methanol and other fuel are not covered in this legislation.
  
• SAF Mandate – sets a legal obligation on aviation fuel suppliers to supply a minimum proportion of SAF, increasing over time. The mandate therefore acts as a key demand‑side policy for HDPs in aviation, alongside parallel SAF revenue support mechanisms. PtL SAF obligations only start in 2028. In addition, there is currently a consultation to broaden the SAF Mandate eligibility to crop-derived SAF for flexibility.
  
• Sustainable Aviation Fuel (Revenue Support Mechanism) Bill – this set the regulation for the proposed revenue certainty mechanism for UK SAF production. The legislation for the revenue certainty mechanism is expected to be finalised by the end of 2026.
  
• Hydrogen Production Business Model (HPBM) – indirectly supports HDPs production by providing revenue support for the hydrogen used for derivatives production. However, hydrogen used to produce energy carriers for export is excluded from HPBM support.

Technology development and standardisation

Technology development and standardisation regulations for HDPs are designed to ensure that when these are used, they are produced, transported and used safely.

There are specific regulations that set the technical, safety and operational requirements for developing and using hydrogen‑derivative technologies. Similar to ‘route to market’ related regulations, they do not actively promote the HDPs sector. However, they affect the way derivatives are deployed in the end-user market.

• The Alternative Fuels Infrastructure Regulations – regulation to ensure a common set of standards and functionality for the provision of certain alternative fuel infrastructure. These alternative fuels include electricity, hydrogen, synthetic fuels – which comprise of HDPs – supplied to vehicles or ships in a way which is consistent across the UK.
  
• Maritime and Coastguard Agency (MCA) Customer Process for Alternative Fuels – Ammonia – IMO have developed interim guidelines for using ammonia as fuel and these can be used by owners/operators wishing to build new vessels or convert existing vessels to run on ammonia. This guidance is used in conjunction with IMO’s International Code of Safety for Ships using Gases or other Low-flashpoint Fuels (IGF Code). The UK policies in Section 4.2.1 have not been clear on the use of ammonia as a fuel. However, this regulation indicates the MCA is preparing for this to be a possibility, which will ease its deployment as a maritime fuel.

Health, Safety and Environment

Health, Safety and Environment (HS&E) related legislation includes the Control of Major Accident Hazards (COMAH) regime and dangerous substances regulations, which govern the safe handling, storage and transport of hydrogen and HDPs.

Table 4 lists the regulations for HS&E pertaining to HDPs. Most of these are not regarded as a barrier to deployment or constraining market activity, but to support the safe delivery of derivatives. Some of the relevant HS&E regulations for derivatives to note are:

• Control of Major Accident Hazards (COMAH) Regulations – these regulations aim to prevent and mitigate the consequences of major accidents involving dangerous substances. They apply to sites that store or handle large quantities of hazardous chemicals. The regulation is based on the mass of the particular substance so will apply to hydrogen derivative thresholds of ammonia (50 tonnes), methanol (500 tonnes), SAF (2500 tonnes). COMAH would apply to all derivatives – but not all projects as dependent on mass of substances.
  
• UK REACH etc. (Amendment) Regulations 2021 – applies to most chemical substances that are manufactured in or imported into England, Scotland, and Wales – and covers all HDPs. This has an associated fee and processing time for registration. The EU has its own REACH rules, which differ from UK REACH. Section 5.1.3 discusses the implications of this.

Consenting

Hydrogen derivative production facilities and infrastructure are subject to planning and permitting under UK regulations governing emissions to air, land and water, waste management and industrial installations, as shown Table 5.

In particular, some relevant regulations to highlight are:

• The Environmental Permitting (England and Wales) Regulations 2016 – governs the environmental permitting and protection controls framework for any industrial and waste installations and its emissions. HDPs storage and transport in England and Wales will be regulated, however this will not apply to hydrogen derivative production facilities in Scotland.
  
• Planning Act 2008 – Nationally Significant Infrastructure Projects (NSIPs) – NSIPs are large scale projects falling into five general categories (energy, transport, water, waste water and waste). This applies primarily to England and Wales. They include projects as diverse as electricity generating projects, reservoirs and hazardous waste facilities. HDPs would fall under Energy and energy infrastructure such as a pipeline carrying HDPs or storage of derivatives.

Cross-border projects covering Scotland and England (such as transport pipelines) will be subject to different regulatory and planning frameworks. For example, for a linear infrastructure project (e.g., cables, pipelines, rail) crossing the border, a project may need a DCO for the English portion, while the Scottish portion requires planning permission under the Town and Country Planning (Scotland) Act 1997. This would also include engaging with two different regulators handling matters – Environmental Agency and Natural Resources Wales regulating England and Wales, and Scottish Environment Protection Agency for Scotland.

European Union

Policy and sector strategy

Europe’s wider strategy and policy for HDPs is informed by the EU Hydrogen Strategy launched in 2020. HDPs are an indirect benefactor of aims to promote the overall demand for clean hydrogen and the recognition that a supportive enabling framework is required to achieve this.

The EU has several initiatives aimed at both promoting the production and use of hydrogen within the economy, with some specifically recognising the role of HDPs. Standing out are the creation of the European Hydrogen Bank and Global Europe Hydrogen Facility designed to accelerate renewable hydrogen deployment by supporting both domestic production and imports to meet 10 million tonnes by 2030. A key aim is to unlock private investment by bridging the price gap between renewable hydrogen and conventional fuels. Additional policy and regulatory frameworks are realised through the EU’s ‘Fit for 55’ Package to reach at least 55% GHG emissions reductions by 2030 compared to 1990 levels.

EU regulatory landscape

Throughout the EU landscape there is a strong focus on route to market-based regulations, with a wide application to the ‘Use’ value chain area.

Route to market

There is significant route to market enablement in the EU via hydrogen specific regulation and policy on HDPs. Standing out in particular are the definitions of what constitutes low-carbon and renewable hydrogen and the eligibility of the resulting products. The assessed regulations are shown in the table below.

There are three key policy instruments within the EU that take direct action in the promotion of hydrogen derivative products:

1. Renewable Energy Directive III (RED III) outlines and defines the eligibility criteria particularly for hydrogen and HDPs. Hydrogen derivative criteria are defined within the description of Renewable Fuels of Non-Biological Origin (RFNBOs) as well as setting minimum mandates for use of RFNBOs across many sectors of the EU economy, including industry and transport. The European approach does not penalise international products provided they also meet the domestic eligibility criteria.There are strict eligibility criteria within RED III for RFNBOs (and the source hydrogen) via Delegated Acts:
   • GHG saving must by >70% compared to fossil equivalent
   • The source of power must be new renewable energy generation that is enabled by the project (alongside temporal and geographical/location constraint of the generating power asset matching hydrogen production with available renewable power generated locally)
   • CO₂ source restrictions must be complied with, particularly fossil fuel-based emissions. As an example, CCS from Natural Gas powered CCGT will be ineligible beyond 2036.
   • RED III requires translation into law by each member state. At the time of writing this study, 25 out of 27 member states have bypassed the deadline to translate into domestic laws.
2. ReFuelEU Aviation sets volume requirements for low carbon aviation fuel, SAF, to be utilised within the aviation sector. The requirements are driven by mandates on transport fuel suppliers. There are specific, time bound targets for the use of SAF and particularly synthetic or e-SAF. The latter does not take effect until 2030.
   
3. ReFuelEU Maritime sets GHG intensity targets for ships over a 5000 gross tonnage calling at European ports. It is agnostic to fuel types or the usage of RFNBOs and does not explicitly require or promote their usage within the stated aims.

The EU definition of RFNBOs includes hydrogen itself and is not exclusive to HDPs. Therefore, any mandated use of RFNBOs throughout the economic zone does not ensure the promotion of HDPs exclusively as they will be competing directly with hydrogen itself.

Enabling policy that is indirectly supportive of low carbon HDPs includes the following:

• European Union Emissions Trading Scheme (EU ETS) which incentivises industry to utilise HDPs to avoid carbon emission penalty costs by capping the allowable volume of carbon emissions per sector of the economy. This prices carbon emissions based on supply and demand within the market and also penalises non-compliance with costs. Sectors include aviation and shipping within the capped allowances. Utilising low carbon fuels such as RFNBOs is recognised to reduce emissions intensity, offsetting exposure to carbon emissions costs
  
• Carbon Border Adjustment Mechanism (CBAM) which aims to protect production of low-carbon goods domestically by exposing non-domestic goods to the same level of domestic eligibility criteria with respect to GHG emissions, or face tariff penalties. This currently only applies to ammonia as a hydrogen derivative, as it is included within fertiliser as one of the five affected sector goods.

The EU ETS states that the emissions cap is agnostic to fuel choice or emissions reduction approach, therefore the adoption of RFNBOs or HDPs is not a direct policy intention. There is, however, a dedicated support mechanism for RED III eligible SAF within the scheme, which both accounts for the lower lifecycle emissions of SAF fuels (reducing the emissions liability of the airline if using SAF) and awards allowances to support price premium of SAF over conventional jet fuel. Similarly, the EU ETS recognises eligible RFNBO fuel usage as reducing the monitored and reported emissions of a stationary installation, and can effectively be used to offset emissions allowance requirements.

Other regulations that are generally supportive of HDPs within the EU include:

• Alternative Fuels Infrastructure Regulation (AFIR) which affects road infrastructure (fuelling stations), airports and ports predominantly. It requires the rollout and installation of alternative fuel supply infrastructure, such as electric charging and hydrogen refuelling. The standards and mandates are not for HDPs, although they are not explicitly excluded from the regulation.
  
• EU Gas Directive & Regulation (2024/1788, 2024/1789) which has been updated to include provisions for hydrogen pipelines and networks. It has recognition of HDPs ammonia and methanol as supply products relating to hydrogen terminals, particularly for the transformation of these products into hydrogen. It does not have specific provision for the transport of ammonia and methanol as energy carriers themselves (i.e., with own pipeline infrastructure network requirements).

Technology development and standardisation

Drop-in hydrogen derivative fuels or e-fuels are accommodated for within existing EU Fuel Quality Directive. This directive specifies the quality requirements for fuels for example in combustion engines, which will apply the hydrogen derivative drop-in fuels.

Health, Safety and Environment (HS&E)

HDPs are accommodated within existing HS&E regulations within the EU such as EU REACH, which requires the registrations of all chemicals produced or imported into the EU above a certain quality. This is a separate registry from the UK REACH. Similarly, the ATEX regulation provide mandated equipment design requirements of pressurised and explosive substances, including HDPs.

Other supportive initiatives

In addition to the regulation discussed above there are other supportive instruments within the EU particularly targeting the growth of the hydrogen and hydrogen derivative sector:

• The European Hydrogen Bank is an EU-level financing instrument that, through its international pillar, supports the import of renewable hydrogen and its derivatives (such as ammonia, methanol, and e-fuels) from non-EU countries into the EU. It functions through the design of mechanisms like joint auctions and incentives to bridge price gaps, ensure sustainability standards, and help meet the EU’s 10Mt annual import target by 2030.
  
• H2Global is a Germany-initiated auction-based funding scheme that facilitates large-scale imports of green hydrogen and derived products from outside the EU/Germany into Europe. The derivatives included are primarily ammonia and methanol. It functions by using public funds to cover price differences between global producers’ offers and European buyers’ willingness to pay, thereby de-risking early projects.

International

Policy and sector strategy

International legislation falls within collaborative organisations that typically have remits for safety, security, and environmental protection. Efforts to progress decarbonisation are prevalent for aviation and marine sectors relating to frameworks for enabling the low carbon fuels including HDPs.

Regulatory landscape

This study reviewed regulations predominantly related to the marine and aviation environment. These are currently the dominating modes of distribution and use of HDPs internationally. The regulatory landscape internally focuses on technology development and standardisation, particular as it pertains to marine vessels.

Route to market

Within the marine sector the IMO has draft legislation targeting decarbonisation which would see a reduction in carbon emissions from combustion of fuels on large vessels over time.

The draft legislation has 2 main policy considerations which may indirectly influence the market of HDPs as low carbon marine fuels:

• Global Fuel Standard (GFS): Sets yearly intensity reduction targets for ship fuel, forcing gradual decarbonization.
  
• GHG Pricing: Imposes costs on emissions above the standard, with two tiers: a lower price for emissions between base and target, and a higher price for exceeding the target.

Technology development and standardisation

All aspects of the value chain of HDPs are applicable to existing international regulations with respect to technology development and standardisation.

The international regulations assessed are described below in relation to three categorisations:

• Marine vessel construction and operation.
• SAF international proliferation (as drop in fuels like eSAF will have less of an infrastructure barrier to adoption as alternative fuels in marine context).
• Fuel specifications

Marine vessel construction and operation

Non-pipeline transport of HDPs relies on the maritime sector and marine vessels. This sector adheres to internationally agreed regulation via the International Maritime Organisation (IMO). Existing IMO codes cover construction, bulk transport and design of vessels utilising HDPs as both a fuel, a refrigerant, and a hydrogen carrier (in the transportation of HDPs). There is an existing risk-based approval pathway within IMO codes for approving new ship types and fuels, via the Alternative Design Arrangement (ADA).

There is also an existing convention particularly for management of marine pollution within the IMO, the International Convention for Prevention of Pollution from Ships (MARPOL). This regulation is effective in limiting pollution from existing marine fuel types, with respect to NOx, SOx, Ozone depleting substances, Volatile Organic Compounds (VOCs), onboard incineration and fuel oil quality. No alternative fuels are included within the fuel type definitions, however, they would be expected to fit within the same rules for pollution. This is particularly relevant for utilising Ammonia as a fuel with respect to SOx emissions. It is expected that this will be managed and controlled by the inherent design of the vessel to ensure the pollution constraints are met (e.g., via the use of selective catalytic conversion technologies onboard vessels).

SAF international proliferation

Global frameworks exist particularly for the promotion of SAF within the aviation industry, via ICAO Global Framework for SAF. Promotion, support and developmental funding is provided via this organisation, of which the UK is a prominent and influential member.

International fuel specification / standards

For the widespread adoption of new fuels (e.g., SAF) standardised testing methods and specification have been created through the American Society for Testing and Materials (ASTM). This is vital for the commoditisation of alternative fuels to be used by aircraft globally. ASTM standards have been developed for all main variants of e-fuel production pathways, ensuring there is no barrier to adoption due to uncertainty of fuel specification.

Health, Safety and Environment (HS&E)

HS&E regulations are typically covered within local jurisdiction, or embedded within the technology development regulations above. It is noted that international carriage of dangerous good by road covers transport of HDPs beyond marine and aviation environments, ensuring full coverage of transport regulations.

Regulatory gap analysis

Our aim in this section is to address the second and third research question of this study. We explore and discuss the gaps and limitations identified within the regulatory landscapes across and between the different jurisdictional levels, categorised by impact area. These impact areas are ‘Consenting’, ‘HS&E’, ‘Route to Market’ and ‘Technology Development / Standardisation’. To aid assessment we initially reviewed each regulation against a set of pre-determined scoring criteria to help categorise and compare before investigating regulations for gaps and limitations as a more granular level. The assessment methodology and output are shown in Appendix A and Appendix B.

Gaps and limitations

The most significant gaps relate to the Route to Market impact area. Our assessment indicated discrepancies in the treatment or definition of HDPs between jurisdictions as well as the exclusion of one or more of the three derivatives covered in this study.

We also identified wider market gaps that do not necessarily arise from the HDPs regulatory landscape. Examples are outlined separately in Section 5.1.55. While not included within our core analysis scope, they provide useful discussion points on potential actions to promote the wider growth of the derivatives market.

Route to market

Route to market regulations show clear jurisdictional discrepancies that complicate offtake opportunities. Impactful regulations were predominantly EU-led regulations, such as RED III and the EU ETS, which offer a comprehensive and clear support framework with established targets and mechanisms that would incentivise offtake and thus a route to market. Particularly supportive for Scottish HDPs production is the openness for international products under RED III and direct inclusion of derivatives under RFNBO definitions. Although these definitions were deemed comprehensive and supportive in terms of allowing international products and different production methods, market participants have also highlighted them as too restrictive in practice (WoodMackenzie, n.d.). European legislations were considered largely outside the direct influence of Scottish and UK Governments.

Key regulations such as Fit for 55 – ReFuelEU Aviation and FuelEU Maritime offer support to HDPs, but are limited by scope. ReFuelEU Aviation is only applicable to SAF and provisions for synthetic SAF are not expected to come into effect until 2030. This timeframe aligns broadly with realistically expected supply timelines. FuelEU Maritime is not explicitly designed to drive HDPs within the maritime sector. With the options of other fuels or electrification being used, the overall market impact of this regulation on HDPs was deemed to be lower.

The UK route to market landscape heavily favours SAF, with limited support for ammonia and e‑methanol. Overall, there is currently an unclear role particularly for ammonia in the UK’s energy system. The topic is expected to be covered in the next UK Government Hydrogen Strategy Update this year, with an overall greater focus and associated support mechanisms required to incentive wider production and use for this derivative type.

Specific support is only available to e-SAF as a hydrogen derivative via the Sustainable Aviation Fuel (Revenue Support Mechanism) Bill and SAF Mandate (Renewable Transport Fuel Obligations (Sustainable Aviation Fuel) Order 2004. An uncertainty within the Revenue Support Mechanism is found in plans to continue stakeholder engagement on the PtL/e-SAF obligation buy-out price at £5 per litre and the mismatch to anticipated high UK production costs. This pricing mismatch may limit uptake and reduce offtake opportunities. Similar dedicated mandates or wider commercial support frameworks currently do not exist for ammonia and e-methanol. In addition, the SAF Mandate currently does not require PtL/e-SAF to be sourced from the UK, placing local producers in competition with overseas markets.

Limitations identified within the current UK ETS system focused on PtL/e-SAF being excluded from zero-rating and users of PtL/e-SAF not being able to claim reduced emissions allowances as is possible within the EU ETS, resulting in uncertainty of application if the UK and EU ETS were to align in the future. Additional uncertainty in the UK ETS stems from the question of whether maritime sectors will be included in future, with a respective consultation planned for 2026. This makes future treatment of e‑fuels in maritime uncertain, limiting potential offtake routes.

A final limitation to highlight is the difference between UK and EU definitions and criteria for HDPs in their respective regulations. Compared to the EU ETS, the UK ETS regulation currently excludes applications in the maritime sector and has no emissions allowance for PtL/e-SAF. UK and EU definitions for SAF and RFNBOs also differ. EU requirements for RFNBOs currently exceed those of the UK, particularly with regard to the geographic correlation for renewable energy sourcing for derivative production. This currently risks reduced export potential for Scottish-produced e-methanol and ammonia if they only adhere to UK requirements.

As highlighted throughout this section, there are opportunities to reduce barriers to offtake and expand the market by seeking greater alignment between UK and EU jurisdictions. A core focus lies in aligning definitions and criteria for HDPs. Additional market engagement with Scottish producers seeking offtake options can help assess the feasibility and impact of further alignment.

Technology development & standardisation

Our analysis of technical standards identified a regulatory landscape with high degrees of certainty and clarity. Although these standards are not designed to promote derivatives, they do not currently represent barriers. Rather, they are enablers by setting the rules and guidance by which technologies and products, including for HDPs (e.g., ammonia fuelled marine engines) will need to abide.

International frameworks exist that cover the three major hydrogen derivative products. Current legislation does not create barriers to their growth, especially for transporting ammonia and methanol, which are already widely traded.

The standards for fuel testing, and promoting the wider usage of new fuels (ASTM), is available for key HDPs already, such as e-SAF (including PtL, Fischer-Tropsch variant), ammonia, methanol and drop-in motor fuels (e.g., e-diesel). With requirements for utilisation of the drop in fuels already regulated under existing legislation e.g., the UK Motor Fuel Regulations (2021).

For marine transport, the IMO IBC Code and IGC Code frameworks, enables transport of substances, such as ammonia as a hydrogen derivative, but not for its use as a fuel. However, there are existing accommodations for alternative fuels such as ammonia and methanol via the IMO IGF code Alternative Design Arrangement. The main gap is the lack of formalised standards for using HDPs outside the risk‑based ADA process. The IMO has released interim guidance for safely using ammonia as a fuel in marine vessels, which is a positive step in accommodating this hydrogen derivative within the sector.

Health, Safety and Environment

We assessed the HS&E regulatory environment as largely-fit for purpose. Regulations are characterised as agnostic to HDPs specifically, thereby not directly targeting or limiting the growth of the market as a policy intent. There is a low degree of influence of the Scottish Government to introduce amendments in European and Global regulations such as EU REACH, EU ATEX directive and the Agreement concerning the International Carriage of Dangerous Goods by Road. There are areas for efficiency and improvement, however, for instance in the current dual burden of complying with both UK and EU REACH regulations if a Scottish producer was to export to Europe.

Consenting and Development

Scotland and the UK have a supportive consenting landscape, with existing regulations already applicable to HDPs specifically. An example of this is the Town & Country Planning Hazardous Substances (Scotland) Regulations 2015. A Hazardous Substances Consent would be required for on-site storage above the thresholds of 50t for ammonia, 500t for methanol and 2,500t for jet fuel.

The Planning and Infrastructure Act 2025 sets out to accelerate the planning and delivery of critical infrastructure – including those for clean energy projects and NSIPs but HDPs are not explicitly covered. The new Environmental Delivery Plans also require clearer guidance for derivative‑specific facilities, creating uncertainty for developers. Establishing additional clarity is important to de-risk the wider value chain for HDPs produced in Scotland, ensuring barriers or complexities in transport or storage outside of Scotland do not impede local production business cases.

Attempts at improving existing regulations and permitting requirements have already been introduced. An example of this is the Environmental Authorisations (Scotland) Amendment Regulations 2025, which seeks to streamline the regulation of waste, water, and industrial activities outside of the overall planning regime. Initial stakeholder feedback has been that it is still too early to establish if the intended outcome has been achieved. We recommend continued monitoring and engagement with stakeholders on these amendments.

Additional regulatory limitations for consideration

We have identified additional market mechanisms and current challenges within the (green) hydrogen production landscape that could be applicable to HDPs. These represent a wider current limitation where a market promoting mechanism is available to hydrogen production, but not to derivatives. They are worth acknowledging when considering the future growth of the HDPs market in Scotland.

• UK power network and policy costs exemptions
  An existing scheme for relief to energy intensive industries offers an exception of up to 90% of Transmission Network Use of System (TNUoS) charges. It is unclear whether electrolytic hydrogen or derivative production will qualify for these exemptions, and for how long this scheme may be active. The Climate Change Levy exemptions currently apply to electrolysis for hydrogen production, reducing the cost of power to green hydrogen producer, however, it is uncertain if further exemptions will follow for power consumed by production of HDPs.
• UK hydrogen‑focused regulations do not extend to derivatives
  Policies such as the Hydrogen Transport and Storage Business Models exclude hydrogen‑derived fuels (e.g., ammonia, e‑methanol), limiting support for derivative project deployment. Similar mechanisms could be considered for and targeted at the derivatives market specifically.
• UK / EU hydrogen certification schemes
  There is a mismatch between recognised standards for certifying low carbon hydrogen utilised within the UK and EU. The UK has a single Low Carbon Hydrogen Standard, with no further standard definition to describe HDPs utilising this hydrogen. Currently, this standard is voluntary unless receiving support via HPBM scheme. The EU, however, has a selection of third-party certification schemes (CertifHy EU RFNBO, ISCC EU, REDcert EU, TUV SUD CMS 70). The lack of a singular certification scheme may lead to additional administrative and cost burden for hydrogen derivative producers.

Intervention areas

Xodus identified the following proposed interventions and recommendations based on the gap and limitations analysis in Section 5.1. Interventions cover specific regulation areas and wider market supporting interventions outside of existing HDP regulation. We suggest that route to market interventions are the main priority, given the existing applicability and suitability of the regulatory landscape to accommodate HDPs across the other impact areas. Xodus recognise that the route to market aspects lie primarily within UK and EU jurisdictions, with more limited direct regulatory influence for the Scottish Government. The interventions thus represent overall engagement and discussion topics to promote greater alignment between jurisdictions to benefit the overall hydrogen derivative value chain.

Intervention 1: Inclusion of e-fuels / e-SAF within UK ETS

• Description: Recognise synthetic renewable fuels used by regulated industries as part of the UK ETS, similar to what the EU ETS currently does – both schemes are misaligned at present. Ptl/e-SAF is currently zero rated in the EU and not in UK. Synthetic fuels should be recognised as low or zero emissions within the emission factor available for fuels, similar to biomass implementation currently.
• Changes would remove potential additional burdens on producers to monitor and adhere to two separate ETS definitions and regimes. Inclusion of synthetic fuels within UK ETS would incentivise further offtake and thus promote market growth.
• Associated regulation: UK Emissions Trading Scheme
• Jurisdiction: UK

Intervention 2: Extend suitable hydrogen funding mechanisms to incentivise the production of hydrogen derivatives

• Description: Existing hydrogen incentivisation models recognise the production of hydrogen and hydrogen derivatives where these are not exported as energy carriers. These could be extended to include the direct subsidisation of ammonia production within the Hydrogen Production Business Model and recognise ammonia as a hydrogen storage solution within the Hydrogen Storage Business Model.
• Impacts focus on promoting deployment and offtake by improving the initial economic viability of production plants. The intervention further addresses the current focus on green hydrogen production and similar funding options for SAF.
• Associated regulation: Hydrogen Production Business Model, Hydrogen Storage Business Model
• Jurisdiction: UK

Intervention 3: Targeted end-use and route to market support for ammonia, e-methanol and other e-fuels

• Description: Implementation of instruments and regulations specific to the use of low carbon ammonia, e-methanol and other e-fuels. Support would require dedicated targets for production and consumption of ammonia and e-methanol in Scotland and the UK. A consenting perspective can aim to promote options for fast-tracking associated production plant applications. For targeted financial support an example is the Advanced Fuels Fund (AFF).
• This recommendation is closely aligned with Intervention 2 on expanding the dedicated route to market and offtake support for ammonia and e-methanol. They consider the current focus on dedicated support for SAF (e.g., through the SAF Mandate and Revenue Support Mechanism). The impact of recommendation focuses on promoting market and offtake demand, thus supporting economic viability for producers.
• Associated regulation: AFF, Hydrogen Production Business Model, similar targeted support for ammonia and e-methanol as found in the SAF Mandate
• Jurisdiction: UK

Intervention 4: Explore options to harmonise the UK and EU definition and eligibility criteria of SAF

• Description: The UK SAF Mandate definition and eligibility criteria for SAF are less restrictive than the EU counterpart. Impacts of aligning requirements focus on enhancing efficiency in offtake across multiple jurisdictions. This reduces burden on producers and supports overall viability, market development and export options from Scotland/UK to EU. It is recommended to explore options and associated impacts to harmonise requirements between the two jurisdictions. Stakeholder engagement with producers can further explore the extent of the issue on available market size.
• Associated regulation: UK SAF and ReFuelEU Aviation
• Jurisdiction: UK & EU

Intervention 5: Support progression of IMO GHG reduction proposals for marine vessels

• Description: Support the representation of UK and Scottish interests within IMO forums. Promote inclusion of hydrogen derivative applications within GHG reduction options for marine vessels in support of the Net Zero Framework. This would impact the overall potential offtake market for HDPs where they are used as a marine fuel. Strengthens a further demand market for produced derivatives.
• Associated regulation: IMO Net Zero Framework
• Jurisdiction: International

Conclusion

This study focused on assessing the regulatory landscape for HDPs in Scotland across key market impact areas and different geographical jurisdictions. We considered relevant Scottish, wider UK, EU and international regulations within the HDP and net zero policy context. Our evaluation of key impact areas covered consenting of hydrogen derivative related infrastructure, route to market regulations, technology development and standardisation as well as HS&E related requirements.

Our assessment of the regulatory landscape showed an existing fit for purpose framework particularly within the consenting, standardisation and HS&E related regulations in Scottish, UK and international jurisdictions. Existing regulations for industrial and traditional fossil-fuel based projects are already directly applicable, even where the overall policy intent is not focused explicitly on HDPs. Examples of this have included COMAH, Pipeline Safety Regulations and UK/EU REACH requirements.

Current limitations and gaps within the regulatory landscape were predominantly found to be within the route to market impact area. The UK regulatory landscape here is skewed towards more dedicated support for SAF production and use compared to e-methanol and ammonia. In addition, as there is currently not a support mechanism for the decarbonisation of marine vessels, there is opportunity for the Scottish Government to intervene and further support this.

Our analysis showed a discrepancy in requirements for HDPs in Scotland/UK compared to EU counterparts. Examples of this included the differences between UK ETS and EU ETS extent and a more stringent RFNBO definition in EU regulations overall.

We recognise that the route- to market regulations lie largely outside the Scottish Government’s direct regulatory influence. Interventions were thus proposed to guide future engagement between Scottish, UK and EU regulatory counterparts, focusing on alignment and standardisation of criteria in HDPs. We consider that improved regulatory alignment across different jurisdictions and more targeted support for all hydrogen derivative offtake will be crucial for the underlying business case of hydrogen derivative production.

Progress in these route to market areas would support the path towards more effectively realising Scotland’s ambitions of becoming a hydrogen derivative exporter. At the same time, any local demand for derivative products could be met with a reduced administrative burden or compliance risk for producers.

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Appendices

Assessment methodology

This section gives a more detailed description of the methodology used to assess and score each regulation reviewed within this report across Scotland, UK, EU and international jurisdictions. The full tabulated results are shown in Appendix B.

We started with a comprehensive desk-based literature review of hydrogen derivative relevant regulations and wider jurisdiction policies. All regulations were captured in an Excel database and categorised according to the following aspects:

• Applicable derivatives: which hydrogen derivative(s) the regulation applies to (ammonia, e-methanol, SAF or combination of these)
  
• Applicability across value chain: which stage of the hydrogen value chain the regulation affects (production, storage, transport or use)
  
• Primary aspect of impact: the market growth or development factor impacted for HDPs, covering:
  • Health, Safety and Environment (HS&E): affects safety requirements, risk management, or operational controls
    
  • Consenting or Permitting: affects planning, permitting, approvals, or regulatory authorisations
    
  • Route to Market: affects demand creation, market access, offtake, or commercialisation
    
  • Technology development or Standardisation: affects technology requirements, standards, or technical development
• Expected impact timeframe: the likely timeframe in which the regulation is expected to have most impact on the HDPs market, split into 0-2, 3-5 or 5+ years.

Where a regulation was judged to impact more than one of the impact areas listed above or could not clearly be attributed to a single category then it was given an impact area labelled as Multiple or Cross-Cutting.

Each regulation was further reviewed for specific applicability considerations and limitations in their treatment of HDPs. Findings were used to shape justifications for each assessment score. The assessment criteria, associated definitions and weightings can be seen in Table 12. A focus was to identify the overall policy intent and market impact of a regulation with regards to HDPs, as well as how clear or certain specific requirements or guidance is.

An acknowledgement of regulations only focusing on one derivative specifically – such as the SAF mandate – was reflected in the lower weighting of scope and breadth of impact. A sub-scoring was also introduced for the degree of regulatory influence – with a higher scoring accounting for direct Scottish Government influence and a 2.5 score for UK-level regulation authority.

Individual scores for each aspect of a regulation were then collated to generate a total score for the regulation’s applicability to, and support for the HDPs market. This then provided an indicator of potential areas of concern and limitations as well as regulations that offered a more supportive environment.

In a subsequent step, these scoring indicators were used to revisit regulations to identify specific gaps and discrepancies between jurisdictions. These were then used to inform potential intervention areas and recommendations.

Regulatory assessment outputs

The full tabulated results are shown by jurisdiction and the primary aspect of impact. Abbreviations are used for the value chain and derivative types, as follows:

• Value chain area
  • Production (P)
  • Storage (S)
  • Transport (T)
  • Use (U)
• Derivative type:
  • Ammonia (A)
  • E-Methanol (M)
  • SAF (S)

Scoring description

The total score shown in the rag review tables on the following pages are weighted averages across the key impact areas with a score between 1 and 3. The total score is a nuanced output, whereby a given score can be used to infer the characteristics of a given regulation, for example:

High scoring (2.5- 3) can be characterised as regulations that are a combination of the following:

• Explicitly designed policy for HDPs that will directly affect a Scotland value chain
• Clear and direct market impact e.g., through targeted support, subsidy, mandates for HDPs and products
• Applies to multiple HDPs across multiple parts of the value chain
• There is a high degree of regulatory influence due to being a regulation under either a Scottish government or UK government jurisdiction

Lower scoring (1.5-2.5) can be characterised as regulations that are a combination of the following:

• Neutral or indirectly supportive regulation for HDPs within a Scottish value chain
• Neutral or indirect effect on the HDPs market, as likely not targeting these substances specifically within the economy
• Applies to a limited number of HDPs (e.g., 1) or only a limited part of the value chain
• The Scottish government has a limited degree of regulatory influence, owing to the fact the regulation is set at beyond the jurisdiction of Scotland or the UK governments (e.g., Internationally)

Scotland full results

HS&E

No Scotland specific regulations were identified for review.

Consenting

The following regulations are all active within Scotland.

Route to market

No Scotland specific regulations were identified for review.

Technology development & standardisation

No Scotland specific regulations were identified for review.

UK full results

HS&E

All HS&E related legislations were deemed to have an impact timeframe of 0-2 years.

Consenting

All consenting related legislation were deemed to have immediate impact timeframes of 0-2 years.

Route to market

Impact timeframes for route to market regulations cover 0-5 years, with the Renewable Transport Fuel Obligations (RTFO) and Sustainable Aviation Fuel (SAF) Mandate Technical Guidance and wider RFTO set at wider 3–5-year timeframes. The Sustainable Aviation Fuel (Revenue Support Mechanism) Bill currently has a longer impact time frame of 5+ years.

Technology development & standardisation

Impact timeframes for the guidance and regulations related to technology development and standardisation are focused on 0-2 year periods, with more immediate, existing impacts.

EU full results

HS&E

These HS&E regulations are currently active.

Consenting

Not reviewed at the European block level. Consenting is specific to local jurisdiction.

Route to market

All regulations are active now and expected to impact within 0-2 years, with the exception of ReFuelEU Maritime which is expected to be long terms 5+ years.

Technology Development & Standardisation

Multiple or cross-cutting.

The expected impact timeframe for HDPs through RED III is 3-5 years.

International full results

HS&E

The ADR regulation below is active now.

Consenting

Not reviewed at the international level. Consenting is specific to local jurisdiction.

Route to market

The IMO Net-Zero Framework is draft legislation with expected impact in the medium term (3-5 years).

Technology development & standardisation

Below are standards / guidance, except for the ICAO Global Framework for SAF which is a Strategy / Policy initiative. All are active with an impact timeframe 0-2 years.

Multiple or cross-cutting.

No regulations fit within this category.

Regulatory map