Low carbon hydrogen is expected to play a critical role in the global energy mix as the world looks to strike a delicate balance between a sustainable transition towards lower carbon energy sources while simultaneously ensuring energy security of supply. As host of COP 28 - the United Nations Climate Change Conference – the UAE continues to take steps towards becoming a global champion for clean energy and accelerated net zero ambitions.

In this article, we explore the country's vision, setting out the key takeaways of the National Hydrogen Strategy and what we know about the UAE's forward direction of travel with the release of the new policy framework for low-carbon hydrogen in the Emirate of Abu Dhabi.

A brief chronology

  • 2021: the UAE's ambitions to position itself as a global hydrogen leader in clean hydrogen technologies were mandated under the leadership of his Highness Sheikh Mohammed Bin Zayed.
  • COP26: the United Arab Emirates Ministry of Energy & Infrastructure (MoEI) released the 'UAE Hydrogen Leadership Roadmap'.
  • 2022: the Abu Dhabi Department of Energy set out to define the framework to position the Emirate of Abu Dhabi as a leader in the production and usage of hydrogen worldwide.
  • 2023: the MoEI published the United Arab Emirates National Hydrogen Strategy.
  • 29 November 2023: the Supreme Council for Financial and Economic Affairs (SCFEA), announced the launch of the new policy framework for low carbon hydrogen in the Emirate.

What is low carbon hydrogen?

While the definition is subject to differences across geographies and different emissions thresholds are expected to be announced internationally, the term 'low carbon hydrogen' is generally accepted to mean hydrogen produced with low or zero carbon emissions at the point of use either produced from low carbon renewable energy with an electrolyzer or from non-renewable sources such as carbon abated fossil fuels with carbon capture and storage (CCUS) for emitted carbon. There are several types of hydrogen; their colour coding is based upon the production method used to create the hydrogen. The colour codes are a helpful reference, but the carbon intensity of the hydrogen production process is a more significant factor. According to the UAE National Hydrogen Strategy "carbon intensity measures the greenhouse gas (GHG) emissions over the entire hydrogen production and “well-to-wheel” lifecycle and is usually expressed in kilograms of carbon dioxide (CO2) equivalent per kilogram (kg) of hydrogen or grams of CO2 equivalent per mega-joule of hydrogen."

Types of hydrogen include:

  • Green: viewed as the cleanest production method, and involves 'electrolysis', where an electric current is used to split water into hydrogen and oxygen. The electricity involved comes from renewable sources and emits zero greenhouse gas emissions;
  • Dark Green: this involves the creation of synthetic gas (or syngas) to generate hydrogen and electricity, through the thermal conversion (such as gasification and pyrolysis) of input materials including municipal solid waste, waste wood and plastic. As a result, Dark Green hydrogen represents an alternative to the burning of waste and landfill;
  • Blue: comes directly from natural gas and a specific production process; e.g. steam reforming, or auto thermal reforming. When hydrogen is produced by splitting natural gas, carbon dioxide is created as a by-product, and 'blue' refers to capturing and storing these CO₂ emissions before they are released;
  • Pink: the same process applied in green hydrogen production, but nuclear energy is the main power source;
  • Grey: the same process as blue hydrogen production but without any efforts to capture the CO₂ emissions; and
  • Turquoise: this involves a production process known as 'methane pyrolysis', being the thermal decomposition of methane into hydrogen and solid carbon. The low carbon assessment of turquoise hydrogen will depend on how the thermal process is being powered.

In the UAE, reference to low carbon hydrogen refers to all colours above except grey. These types of hydrogen are of relevance to the UAE and are specifically referenced within the National Hydrogen Strategy. It is, however, also worth pointing out that 'yellow' hydrogen is commonly discussed in addition to the above, which is hydrogen produced purely from solar power.

Key takeaways from the UAE National Hydrogen Strategy

The aim of the UAE National Hydrogen Strategy is for the nation to be a top global producer of low carbon hydrogen by 2031. The most noteworthy takeaways are:

  1. Targets: hydrogen production of 1.4 MTPA per annum by 2031, rising to 15 MTPA by 2050.
  2. Hydrogen Oases: establishment of two "hydrogen oases" (or clusters) by 2031, and five by 2050, likely to be located near depleted oil wells for carbon storage and potential connections to salt caverns for high-volume storage.
  3. Emissions: reduction of emissions in hard-to-abate industries, 25% by 2031 and 100% by 2050.
  4. Types: the strategy is clear that the UAE is open to exploring pathways to developing all colours of hydrogen.
  5. Finance and Investments: provide project funding and financing to support developers in all areas of the low carbon hydrogen supply chain is a key priority, including the establishment of the Hydrogen Innovation Fund as a policy priority with dedicated funding toward research and innovation.

Abu Dhabi Low Carbon Hydrogen Policy

The UAE's National Hydrogen Strategy preceded the launch on November 29 by SCFEA - the authority responsible for setting the public policies and approving the governing strategies of the financial, investment, economic, petroleum and natural resource affairs in Abu Dhabi - of the new policy framework for low carbon hydrogen specific to the Emirate.

While we continue to watch this space for the details on what the Abu Dhabi Low Carbon Hydrogen Policy contains, SCFEA did confirm that the policy will outline key principles that:

  • Define the framework for the low carbon hydrogen industry.
  • Enable cooperating between the hydrogen, natural gas, and electricity sectors.
  • Provide the necessary flexibility for industry leaders.
  • Set technical standards for safety and consumer protection.

A clear regulatory framework is a priority enabler and still required to govern the entire hydrogen supply chain from production to end-use, earmarked in the UAE for development between 2023 and 2025. Globally, the hydrogen value chain development is in its infancy.


Marc Penman

Senior Solicitor, Brodies LLP