The firm analysed existing Commonwealth, state and territory legislation and regulations in the hope of further informing work on the National Hydrogen Strategy, ENA said.
The objective was to identify possible regulatory roadblocks, but does not consider the operational side of hydrogen injection.
It is also only concerned with gas legislation and not safety, development or environmental legislation.
"There is nothing in the National Gas Law which prohibits the injection of hydrogen or biogas into an existing distribution network," the report said.
As hydrogen is not ‘natural' it cannot be covered under existing law, which may have to be changed to accommodate it.
"There are no provisions in the National Gas Law which would affect the operation of a pure hydrogen or biogas network," it found.
This is because the National Gas Law would not apply to a pure hydrogen network as it regulates pipelines for the haulage of natural gas and the service providers, who own, operate and control those pipelines.
"Pure hydrogen is not ‘natural gas' within the meaning of the National Gas Law," it said. Neither is biogas "unless the biogas constitutes ‘natural gas' within the meaning of the National Gas Law".
"If network operators wish to develop pure hydrogen networks or biogas networks, there is a question as to whether the law should be changed so that those networks are subject to the regulatory framework that applies to natural gas networks under the National Gas Law," it said.
"The law will require amendment if it is desirable for a hydrogen or biogas network to form part of a wholesale gas market, a short term trading market, a gas trading exchange or a retail gas market."