Hydrogen: Developments in Singapore and around ASEAN

Introduction

ASEAN has abundant resources required to produce green, blue, and grey hydrogen, and the development of new technologies and supply chains has helped to bring down the cost of hydrogen energy and fuel cell applications.

Hydrogen is therefore increasingly positioned as a core decarbonisation lever across Southeast Asia. Several ASEAN Governments have published hydrogen roadmaps and national strategies, but the legal and regulatory frameworks underpinning these ambitions remain at varying stages of maturity. In most jurisdictions, hydrogen is currently governed through existing energy, environmental and industrial safety regimes rather than standalone hydrogen legislation. 

This update reviews recent regulatory and project developments in Singapore, Malaysia (including Sarawak), and Indonesia.

Singapore 

At COP27, Singapore submitted its strengthened Long-Term Low-Emissions Development Strategy (LEDS), committing to achieve net zero emissions by 2050. It also updated its 2030 Nationally Determined Contribution (NDC), targeting emissions of approximately 60 million tonnes of carbon dioxide equivalent by 2030. 

A key pillar supporting these targets is Singapore’s National Hydrogen Strategy, formalised in October 2022. The strategy identifies hydrogen as a potential major decarbonisation pathway, particularly for the power sector, where it is expected to complement solar deployment, imported electricity and other low-carbon energy sources to diversify Singapore’s energy mix^[1].

Regulatory Position

Singapore does not currently have hydrogen-specific legislation governing hydrogen as an energy resource. Instead, hydrogen-related activities are regulated under existing legislative frameworks, including: 

• the Electricity Act 2001 (in respect of power generation facilities);
• the Workplace Safety and Health Act 2006;
• the Fire Safety Act 1993; and
• other hazardous substances and industrial safety regulations. 

The Energy Market Authority (EMA) is studying the legislative and regulatory changes required to support hydrogen deployment in the power sector^[2]. This includes consideration of: 

• infrastructure requirements for hydrogen import, storage and conversion;
• technical standards and safety codes for hydrogen transport and use;
• potential regulatory frameworks for hydrogen-ready power generation assets. 

Singapore’s approach remains strategy-led and Government-driven with regulatory preparedness and safety considerations forming the foundation for future deployment.

Malaysia (Federal)

Malaysia launched its Hydrogen Economy and Technology Roadmap (HETR) on 5 October 2023, positioning hydrogen as a key pillar under the National Energy Transition Roadmap (NETR) and the National Energy Policy 2022–2040^[3]. The HETR sets out Malaysia’s ambition to become a regional leader in hydrogen production, utilisation and export by 2050, identifying hydrogen as one of the key energy transition levers in the country’s decarbonisation strategy^[4].

In July 2025, Malaysia announced the launch of the Hybrid Hydro Floating Solar (HHFS) and Green Hydrogen Hub in Terengganu, a collaboration between PETRONAS and Tenaga Nasional Berhad (TNB). The initiative is structured as an integrated end-to-end value chain encompassing renewable energy generation (including the Kenyir HHFS facility), green hydrogen production, and downstream derivatives such as green methanol and green ammonia^[5].

Regulatory Position

Malaysia has not yet enacted a hydrogen-specific legal framework at the federal level. Hydrogen activities are currently regulated through existing legislation, including: 

• the Gas Supply Regulations 1997;
• the Environmental Quality Act 1974; and
• the Street, Drainage and Building Act 1974, among others.

The federal framework therefore remains policy-driven, with hydrogen governed through established energy and environmental regulatory regimes.

Sarawak

Sarawak has taken a more concrete legislative step towards formalising hydrogen regulation.

The Sarawak Hydrogen Economy Roadmap (SHER), launched in May 2025, outlines the state’s strategy to leverage its renewable energy resources, natural gas and carbon capture capabilities to scale low-carbon hydrogen production. SHER forms part of Sarawak’s broader clean energy strategy, which includes the Sustainable Energy and Technology Plan (SET-P), focusing on power, transportation, industry, and buildings^[6].

Sarawak’s hydrogen ambitions are reflected by two flagship projects^[7]: 

• Project H2biscus is a collaboration between the Sarawak Economic Development Corporation Energy (SEDC Energy) and South Korean giants Samsung Engineering, Lotte Chemical and POSCO. The project is slated to have an annual capacity of 150,000 tonnes and a green ammonia conversion plant with a capacity of 850,000 tonnes for export to South Korea.
• Project H2ornbill is a collaboration between SEDC Energy and Japanese counterparts Sumitomo Corporation and ENEOS. The project is slated to generate 90,000 tonnes of green hydrogen annually for export to Japan, including 2,000 tonnes for Sarawak’s consumption.

Regulatory Position

In November 2024, Sarawak passed amendments to its Distribution of Gas Ordinance, expressly extending the regulatory framework to cover hydrogen generation, storage, transportation for distribution, and export^[8]. While not a standalone Hydrogen Act, this amendment brings hydrogen within a defined licensing regime and represents one of the most concrete legislative steps in ASEAN towards hydrogen-specific regulation.

Indonesia

Indonesia launched its National Hydrogen Strategy in December 2023 and its National Roadmap for Hydrogen and Ammonia (NRHA) in 2025, positioning hydrogen as a key enabler for achieving its net-zero emissions target by 2060. The NRHA targets 4.2 million tons of hydrogen consumption for power generation annually by 2060, and outlines 215 action plans across regulatory, infrastructure, and export development phases^[9].

The NRHA is structured across three implementation horizons^[10]: 

• a short-term phase focused on establishing the necessary regulatory and policy framework;
• a medium-term phase aimed at infrastructure integration, investment mobilisation and hydrogen hub development; and
• a long-term phase directed at positioning hydrogen as a strategic export commodity.

Indonesia has not yet enacted a comprehensive hydrogen-specific statute. Specific laws governing hydrogen blending, pipeline transport or hydrogen-specific safety regulation remain under development or in draft form. As with other ASEAN jurisdictions, hydrogen activities are presently governed through existing energy, environmental and industrial safety frameworks.

Possible Roadmap

To advance the hydrogen economy in ASEAN, we believe that more work and governmental support will be essential, along with financing options for hydrogen development. This includes (hopefully ASEAN-wide) concerted efforts to:

1. establish a base standard of green hydrogen production, possibly from renewable energy, biomass and even nuclear energy;
2. identify potential barriers, pathways, and opportunities, to transition to a clean hydrogen economy;
3. identify economic opportunities for the production, processing, transport, storage, and use of clean hydrogen;
4. identify ESG risks associated with potential deployment of clean hydrogen technologies, and ways to mitigate those risks; and
5. identify opportunities to use, and barriers to using, existing infrastructure (such as the natural gas infrastructure system, for clean hydrogen deployment.

Concluding Observations

Hydrogen regulation in Southeast Asia remains uneven and transitional. While national strategies and roadmaps are increasingly detailed, comprehensive hydrogen-specific legislation remains limited. Among the jurisdictions reviewed, Sarawak stands out for having formally amended its gas legislation to accommodate hydrogen within a defined licensing regime, whereas Singapore, Malaysia (federal) and Indonesia continue to rely primarily on existing statutory frameworks. 

For investors and project developers, this regulatory divergence underscores the importance of jurisdiction-specific assessment. In the absence of harmonised hydrogen legislation, projects must be structured with careful attention to licensing pathways, safety compliance, infrastructure regulation and potential change-in-law exposure. As hydrogen initiatives evolve from pilot programmes to commercial-scale production and export platforms, regulatory clarity — particularly in relation to certification, storage, transport and cross-border trade — will be critical to unlocking bankable hydrogen investments across ASEAN.

This article is produced by our Singapore office, Bird & Bird ATMD LLP. It does not constitute legal advice and is intended to provide general information only. Information in this article is accurate as of 2 March 2026.