CMP441: Reducing the credit risk of supplying non-embedded hydrogen electrolysers
What is being proposed
This modification seeks to address a discrepancy in the timing in de-energising a non-embedded hydrogen electrolyser verses an embedded hydrogen electrolyser
Current status
The Proposal was presented to the September 2024 CUSC Panel, where the Panel unanimously agreed that CMP441 should follow the Standard route and proceed to a Workgroup. The Panel agreed the Terms of Reference for the Workgroup. Post Panel feedback the Proposer updated their solution l requested a Straight to Code Administrator Consultation route at the October 2024 CUSC Panel. The October 2024 Panel agreed that the Proposer had updated their solution so that it could proceed straight to Code Administrator Consultation. The Code Administrator Consultation was published on 29 October 2024 and closed at 5pm on 19 November 2024. DFMR was presented to the December 2024 CUSC Panel. The Panel recommended unanimously that the Proposer’s Original solution is implemented. The Final Modification Report was submitted to the Authority on 23 December 2024. This modification expected decision date is 02/07/2025. On 28 July the Authority sent back this modification for Panel to consider its next steps. This will be presented to Panel on 22 August 2025. (08/09/2025) In the postponed 03 September Panel, the Panel moved this modification prioity to low.
Details
Timeline
Analysis
CMP441 proposes to align the timing for de-energising non-embedded hydrogen electrolysers with embedded ones, addressing a credit risk discrepancy. The modification was unanimously recommended by the CUSC Panel in December 2024 but was sent back by the Authority in July 2025 for reconsideration. The Panel has now deprioritised it to low priority status.
Why it matters
This targets a minor technical inconsistency that creates unnecessary credit exposure differences between similar hydrogen production assets. The Authority's rejection and subsequent deprioritisation suggests the fix may be premature given the nascent state of the hydrogen electrolyser market.
Key facts
- •Panel unanimously recommended implementation December 2024
- •Authority rejected modification July 2025
- •Expected decision date was 2 July 2025
- •Now deprioritised to low priority status
- •Low impact on customers, suppliers and TSOs