Portugal and Slovakia are the only members of the European Union's twenty-seven to have notified the European Commission of national measures transposing Directive (EU) 2024/1788, two days before the deadline of Wednesday 5 August 20261. The directive recast the bloc's rules for its internal markets in renewable gas, natural gas and hydrogen. Its Article 94 requires transposing measures to be in force by that Wednesday.
Portugal lodged Decreto-Lei n.º 94/2026 of 30 April 2026, whose own title calls it a transposição parcial, a partial transposition, covering this directive and the Energy Efficiency Directive together. Slovakia lodged Zákon č. 259/2025 under the register annotation "Member State does not consider the transposition necessary"2. Bratislava has told Brussels it sees no new domestic law as needed. Lisbon has told Brussels it has written part of one.
EUR-Lex records notifications to the Commission, not the contents of national gazettes. Filing lags legislating as a matter of routine, and a capital can have a statute in force with nothing yet standing against its name in Brussels. What the register supports is the narrow reading, and the narrow reading still merits a desk's attention: two governments have told the Commission they have transposed, on a deadline whose listed articles run to unbundling, certification of transmission and distribution system operators, third-party access, tariff principles for gas and hydrogen networks, network development planning, storage and LNG facility access, and supplier switching3.
Missing a transposition deadline starts a documented procedure rather than a fine. the Commission's April infringements package issued reasoned opinions against Croatia, Poland and Portugal over a separate electricity directive, leaving those three one procedural step short of a referral to the Court of Justice. The instruments that actually landed across the past fortnight came from agencies rather than parliaments: ACER published an EU-wide generation investment-cost dataset on 30 July, and CRE authorised experimental local flexibility markets on the RTE and Enedis platforms the same day. Harmonised hydrogen network access cannot arrive that way. It needs twenty-seven legislatures, and so far two of them have said anything at all.
