What BE.Hydrogen Is — and Is Not

The programme, funded from EU ETS revenues and carried by the Royal Belgian Institute of Natural Sciences, is a geological survey: seismic mapping, geochemical sampling, subsurface modelling. It is not a production project, not a discovery announcement, and not a commercial venture. The Belgian government has been explicit that the initiative targets potential deposits, and no flow rates, reserve estimates, or exploitable accumulations have been identified. Treating the survey as anything more would misrepresent both its scope and its findings to date.

The technical rationale is nonetheless sound. Geological hydrogen — produced abiotically via serpentinisation of iron-rich ultramafic rocks — has been confirmed at commercially interesting concentrations in Mali, Australia, and the Canadian Shield. Whether analogous formations exist in the Belgian subsoil is precisely what the €3.5 M programme is designed to determine, using the same geophysical and geochemical methodologies now being standardised in the peer-reviewed literature on natural-hydrogen exploration.

The RED III / RFNBO Certification Gap

Under RED III’s delegated regulations, hydrogen qualifies as a Renewable Fuel of Non-Biological Origin (RFNBO) if it is produced by electrolysis powered by additionality-compliant, temporally- and geographically-correlated renewable electricity. That definition is electrolyser-centric by design. Geological hydrogen involves no electrolysis and consumes no renewable electricity — which is precisely the argument that makes it attractive from an energy-efficiency standpoint: the crushing well-to-wheel penalty of e-fuels (roughly five times more electricity per kilometre than a battery-electric vehicle) disappears when the hydrogen is extracted rather than manufactured. But the same characteristic means geological H2 cannot be certified as an RFNBO under current rules, and therefore cannot count toward ReFuelEU’s e-SAF sub-mandates or RED III renewable targets without a new delegated act or certification methodology.

The European Commission has not tabled any proposal to extend RFNBO certification to geological hydrogen. Any Belgian commercial discovery would require a dedicated LCA methodology, a chain-of-custody standard, and likely a revision to Annex IX or a new delegated regulation — a legislative timeline measured in years, not months. Compliance officers and project developers should model geological H2 under a ‘policy-risk’ scenario rather than assuming regulatory equivalence with electrolytic production.

Technical Monitoring and the Role of Data Infrastructure

If exploration does identify viable formations, the data architecture required for regulatory compliance will be substantial. RFNBO certification — or any future geological-H2 equivalent — demands continuous monitoring of production volumes, purity, fugitive emissions, and upstream GHG intensity. In the electrolysis sector, this is increasingly managed through digital twins and AI-assisted sensor fusion that can generate the audit-grade data streams regulators require. The same logic applies to geological extraction: subsurface flow monitoring, real-time compositional analysis, and automated reporting pipelines are prerequisites for any certification regime, not optional add-ons. Belgium’s survey phase is the moment to architect those data standards, before commercial pressure forces shortcuts.

For the broader e-fuels ecosystem, the Belgian initiative is a data point worth tracking: if geological hydrogen can be certified at competitive cost, it could supply feedstock to PtL and e-SAF plants without the electricity-intensity penalty that currently constrains green hydrogen economics. That would materially change the business case for Power-to-Liquid in regions with geological H2 access — but only once the regulatory pathway exists.

Sources

• Natural hydrogen exploration methods and identification of sources: A comprehensive overview — ScienceDirect

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