Published: March 31, 2026.
Written by Carbon Balance Initiative, Clean Air Task Force, and Bellona Europa.
Article 23 of the Net Zero Industry Act (NZIA) introduces a novel regulatory obligation requiring oil and gas producers operating in the European Union to contribute to the development of 50MtCO2 per year of injection capacity by 2030. This report provides the first annual state-of-play assessment of the implementation of Article 23 through the Article 23 Watch Initiative, a joint project by Carbon Balance Initiative, Bellona Europa, and Clean Air Task Force. The report examines progress by obligated entities and Member States, complemented by stakeholder perspectives and emerging litigation developments.
Overall, the analysis suggests that Article 23 is already influencing storage project development and policy planning across Europe. However, achieving the Union-wide target will depend on addressing regulatory uncertainties, strengthening Member State implementation, and accelerating the development of the broader CCS value chain.
