CCS in Europe and the NZIA

• Article 20 of the NZIA (Regulation (EU) 2024/1735) sets an EU objective of at least 50 million tonnes per year (Mtpa) of CO2 injection capacity by 2030. Article 23 divides that objective between EU oil and gas producers.
• Each producer's share is in proportion to its share of EU oil and gas production from 2020 to 2023. Commission Decision (EU) 2025/1479 names the 44 companies concerned (the obligated entities) and their individual shares. This briefing does not comment on individual companies' obligations.
• Only injection capacity at storage sites in the EU, including its offshore economic zones and continental shelf, that are permitted under the CCS Directive (2009/31/EC) counts, and it must be available to the market by 2030. Storage in the UK and Norway does not count under the law as it stands, and nor does storage combined with enhanced oil or gas recovery.
• To comply, obligated entities need to show qualifying permitted injection capacity available to the market by the end of 2030, at sites designed to operate for at least five years with fair and open access. They can develop storage themselves, agree with other obligated entities, or contract with third-party storage developers or investors. A final investment decision (FID) shows progress but is not compliance. A storage agreement with an emitter may help show that capacity is available to the market, but the Regulation does not define it as a means of compliance.
• The Commission published its first progress report in May 2026; the next is due by 30 June 2027.

EU CO2 injection capacity by 2030 (Mtpa)

The Commission's first progress report (May 2026) lists three EU sites holding a storage permit under the CCS Directive: Porthos (Rotterdam), Greensand (Danish North Sea) and Prinos (northern Greece), with about 3.5 Mtpa between them. A further 15.6 Mtpa was going through permitting. Since then, all three Aramis stores in the Netherlands have been permitted (Shell's K14-FA/FC in May, TotalEnergies' L04-A in July and Eni's L10-ALBE on 30 September), so six EU sites now hold permits. The Aramis partners still plan to start in 2030, but the Dutch government expects 2031, after a final investment decision in 2027.

Member States' own reports add up to 33 Mtpa by 2030. In March 2026, Article 23 Watch, which tracks the obligation, estimated 43 Mtpa from announced projects, with 50 Mtpa reached closer to 2032. In June 2026, IOGP Europe reported that ten announced projects had since been cancelled or postponed, cutting announced EU capacity by 2030 to about 35 Mtpa. Only 2.9 Mtpa had reached a final investment decision. Wood Mackenzie expects the EU to fall at least 17.5 Mtpa, about 35%, short of the objective, even if every project in advanced development goes ahead.

Not everyone is as pessimistic: the Global CCS Institute's Head of Europe still calls 50 Mtpa achievable, pointing out that Europe has 13% of the world's operational CCS projects and more than a third of the global pipeline under construction. Permitted capacity is small compared with the objective at the time of writing and, from the perspective of obligated entities, much of the storage capacity coming online soon is already taken by owners' own obligations or regional emitters.

• Twelve obligated entities filed fifteen cases at the EU General Court in October 2025, challenging the Commission decision that sets their shares of the obligation, and the principle of the obligation under the NZIA. The cases are pending and do not suspend the obligation.
• In August 2026 ExxonMobil gave notice of an arbitration claim over the obligation under the Energy Charter Treaty, an international investment-protection treaty. A cooling-off period must pass before arbitration can begin.
• Member States were due to set penalties for non-compliance by June 2026. Germany indicates c.130 to 145 EUR/t; most others have no compliant regime.

EU stores (count under Article 23)

Non-EU stores (do not count as drafted)

UK stores. The UK Autumn Budget prioritises CCUS projects in Teesside, Merseyside and North Wales, and keeps grant funding for Viking CCS in the Humber, but saves GBP 200m from CCUS capital grants. That leaves Acorn in north-east Scotland without confirmed grant funding; future government support moves to loans and equity. Separately, the Northern Endurance Partnership (bp, Equinor and TotalEnergies) has completed a two-well appraisal of two potential stores on its CS006 and CS007 licences, alongside Endurance. It plans FEED for this expansion in 2027 and FID in 2028; Endurance itself remains on track to start in 2028. Indicative heads of terms have also been published for Transition Access Agreements, under which projects pay all transport and storage charges up to an agreed per-tonne threshold.

Sweden pays only for stored CO2. The Swedish Energy Agency has awarded SEK 9.3 billion (c.EUR 840m) by reverse auction to three waste-to-energy operators to capture and store 5.75 Mt of biogenic CO2, the CO2 released from burning the biomass share of waste. Storage must start within four years and payment is made only once CO2 is stored. Including Stockholm Exergi's project, c.17 Mt is expected to be stored by 2046.

• Sweden has no storage of its own, so this is new demand for North Sea capacity, much of it outside the EU. Öresundskraft has already contracted with Northern Lights.
• Yara's carbon capture plant at Sluiskil in the Netherlands, inaugurated in September, will capture about 800,000 tonnes a year for shipping to Northern Lights.
• EU Innovation Fund, the grant programme funded by Emissions Trading System revenues: the 2025 round (announced 20 October) awards EUR 3.4bn to 77 projects and was oversubscribed in every category. Ravenna Phase 2 selected; Atlas awarded EUR 223m, conditional on FID in 2028.
• EU Emissions Trading System (ETS) review (COM(2026) 616, July): the Commission proposes using 250 million allowances in 2031 to 2040 to buy permanent carbon removals within the EU. Negotiations between Parliament, Council and Commission are targeted for Q1 2027.
• Austria: CO2 storage is currently banned. A draft CO2 Storage Act would lift the ban; consultation closed on 30 October. OMV, Austria's largest oil and gas company, has an Article 23 share of 0.96 Mtpa.

CCUS 2026 is the Carbon Capture and Storage Association's UK conference, held at Central Hall Westminster, London, on 13 and 14 October. It brings together project developers, emitters, government, lenders and insurers. I attended both days. What stood out:

• Storage is operating commercially, but spare capacity for third parties is thin. Early capacity at the first EU stores is largely spoken for, and new third-party capacity depends on expansion phases and new hubs.
• The finance community sees capital as available and geological risk as acceptable to some banks. Revenue certainty, utilisation and cross-chain risk allocation decide bankability.
• How an asset is held and financed, for example the split between debt and equity, can move storage cost by around 20 EUR/t: roughly 50 against 70 EUR/t.
• The hardest risk to insure is business interruption without physical damage: when injection stops or slows, revenue stops.
• The UK and continental markets are moving from state-backed first projects towards aggregators, which collect CO2 from many smaller emitters and contract transport and storage on their behalf. A fully commercial market without state support is expected in 10 to 15 years (don't hold me to this).
• Norway is positioning itself as Europe's storage provider, pointing to the Northern Lights expansion from 1.5 to 5 Mtpa and 10 storage exploration licences. Norway's Minister of Trade and Industry set this out in a keynote.
• NZIA was not on the agenda in its own right, but industry pressure for UK and Norwegian stores to count is growing.

• Permitted EU capacity for 2030 sits in a handful of stores, and several of those are already taken by owners' own obligations or regional emitters.
• Obligated entities without their own storage are likely to need contracted access to permitted capacity available to the market by 2030. An FID or an agreement with an emitter does not meet the obligation on its own.
• Pay-on-storage schemes such as Sweden's add demand for North Sea capacity, much of it outside the EU.