We operate in an extremely dynamic environment. External and strategic risks largely determine Gasunie’s current risk profile. In determining strategy and making decisions, we always strive for an optimum balance between risk and reward. Our risk appetite serves as a guideline in this.

In our operating activities, risk management supports the organisation in mitigating the risks to an acceptable level. In determining what is acceptable, we are increasingly vigilant to avoid too great a risk aversion, which could result in ‘over-control’ and sluggishness. Operating safely and reliably is a precondition for all activities.

Overview of important risks

In the diagram below, we have included our important risks in key words. We make a distinction between avoidable risks (operational, reporting and compliance), strategic risks and external risks. For an explanation of this categorisation, see Risk management. The position in the diagram indicates the relationship with our risk appetite. Risks in the orange and red band exceed our risk appetite, risks in the green and yellow band fall within it.

The diagram indicates the residual risk, i.e. taking into account the control measures already taken. The time horizon is 5 to 10 years for strategic and external risks, and up to 5 years for risks of a more operational nature.

The tables below provide further explanation of the risks/key words above. We have included the relationship with our three strategic pillars, as well as an overview of the important mitigating measures that we take.

Avoidable risks What important measures do we take?

Disaster in the Gasunie network: explosion, major failure to deliver, serious accident. (I:E)



Strategic pillar I

  • Very extensive system of control measures.
    • With the continued development of Risk-Based Asset Management, the risk profile can, on certain points, shift within the bounds of our acceptance.
  • Active incident monitoring.

ICT security: never 100% certainty, when is it good enough? (O:B)


  • Thorough package of control measures, certified and externally tested.
  • Behavioural component remains a difficult factor to manage: attention to raising awareness.

Nitrogen plant: delayed completion, performance problems, major budget overrun. (O:D)

Strategic pillar I

  • Professional project organisation.
  • Thorough realisation of the social importance among the team.
  • Extra management attention.

Compliance: failure to fully comply with laws and regulations and internal rules. Safeguarding our licence to operate. (O:C)


  • Careful environs management.
  • Risk-averse, very controlled organisation.
  • Thorough realisation of our social role and special position.


Strategic risks What important measures do we take?

Strategy in relation to the energy transition: failure to create and capitalise on serious opportunities. The energy transition could also conceivably involve logical growth paths in which Gasunie is not needed. (III:A)




Strategic pillar III

  • Targeted choice of focal points.
  • Take an active stance in initiatives and actively approach strategic partners.
  • Contribute actively to the political and social discussion by providing knowledge and experience.
    • Our knowledge and independent position can serve as a strength in the discussion, the traditional relationship with fossil fuels can work against us.

Strategy for Germany: failure to implement the strategy, for instance: market integration does not get off the ground, participation in German LNG proves not to be feasible, politically or otherwise. (II:A)

Strategic pillar II

  • Gasunie Deutschland as springboard for new activities in Germany.
  • Actively approach parties in relation to market integration and cooperation.
  • Initiative with good JV partners for LNG, actively include shareholder.

Organisation is the limiting factor: the development of the required leadership is still not effective enough; a voluntary severance scheme may cause shortage. (O:A)

  • Start of a new leadership programme.
  • The voluntary severance scheme has a cap on the number of participants.


External risks What important measures do we take?

When a new regulatory period takes effect, the outcome is unpredictable because of the benchmark method used. This could have a major financial impact. (I:A)

Strategic pillar I

  • Dialogue with ACM concerning the method to be used.
  • Respond promptly to situations that could negatively affect a (new) benchmark.
  • Challenge in court any unreasonable outcome.

Rapidly declining gas consumption has a negative effect on the utilisation rate of the Gasunie network and on the liquidity of TTF. The current regulatory model could become untenable in the long term. (I:B)

Strategic pillar I

  • Actively develop the alternative use of the network: green gas, hydrogen in the long term.
  • Participate in the political and social discussion on the role of gas (natural gas, green gas, hydrogen) in the future.
  • Think ahead (in cooperation with ACM) on the long-term possibilities for regulation.

Geopolitics: for a few activities that are susceptible to new or existing US sanctions that also affect Europe; dependency on third parties like Gazprom for some activities. (II:B)

Strategic pillar II
  • Alertness to US sanctions in the event of new activities.
  • Contractual mitigation of uncertainties.
  • Quick assessment of current developments.

In the event of natural gas shortages, GTS may be asked (by local communities) to undertake action that is not in line with its role. (I:D)

Strategic pillar I
Consultation with the Ministry of Economic Affairs and Climate and regional network operators on roles and expectations.

Security of supply: the system is becoming increasingly dependent on foreign natural gas and quality conversion. The loss of the Groningen gas field as a back-up increases the likelihood of shortages of G-gas (and in Germany, L-gas). (I:C)


Strategic pillar I
  • Thorough advising of the ministry on the speed at which the extraction of Groningen gas can be phased out.
  • The construction of a new nitrogen plant for quality conversion of H-gas to Groningen quality.
  • Enable the extra supply of nitrogen by third parties.