The 5th Industrial Carbon Management (ICM) Forum took place this year on 8-9 December in Athens, Greece, co-hosted by the European Commission and the Greek Ministry of Environment and Energy [1]. For the first time, the Forum moved away from its historically North Sea focus, drawing attention to emerging Mediterranean CO₂ storage developments. Greece’s Prinos CO₂ storage project – planned as the first commercial-scale CO₂ storage site in the Southeast Mediterranean – received significant attention through several presentations.  

Geographic diversification of CO₂ infrastructure has the potential to help level the playing field for industries with no or limited access to the North Sea. Greece is concurrently rolling out a national CO₂ pipeline network – ApolloCO₂ – to connect heavy emitters to Prinos. In practice, this includes linking several major EU-backed projects, such as Holcim’s Olympus cement CCS plant, Titan Cement’s Ifestos project, and Motor Oil Hellas’ IRIS CCUS project, collectively preparing to capture several million tonnes of CO₂ that would otherwise be emitted. 

The attendance at the Forum in Athens didn’t reach the heights of the previous year. In fact, it fell compared to last year’s Forum in Pau: 420 in-person and ~300 online, down from over 500 and more than 2,500 online the previous year. The relatively low attendance may be explained by the very late publication of the event’s agenda, and hopefully should not be read as foreshadowing a decline in momentum around CCS following an otherwise strong year marked by the publication of NZIA obligations for 44 oil and gas entities [2], a new wave of Innovation Fund grants, and several new PCI/PMI project announcements. 

Bellona was once again represented at the Forum this year. We continue to view civil society participation as essential to ensuring that the core objective of CCS deployment, the rapid emissions reductions in hard-to-abate sectors, is not overshadowed by narrow commercial interests, and that broader societal and environmental concerns remain central to the debate.  

Bellona, although not part of the panel lineup this year, participated through interventions and co-organised a pre-Forum networking reception on the 7^th of December with CCS Europe as well as Article 23 project partners, CATF and Carbon Balance Initiative. The discussion focused on the implementation of the Net-Zero Industry Act (NZIA) and highlighted several pressing themes, including the need to address the gap between the pace capture project development and storage availability, the urgency of moving from planning to delivery of the 50 Mt of annual CO₂ injection capacity by 2030, and the high stakes for European industrial competitiveness. 

As in previous years, civil society representation on stage remained limited, with only one NGO (Carbon Gap) and one think tank (Agora Industry) speaking on panels. This continued imbalance highlights the need to broaden participation in future editions of the Forum to better reflect societal interests and safeguard the climate integrity of CCS policy discussions. 

Despite broad stakeholder representation, gender balance on stage was strikingly poor: only one out of six panels met gender parity.  This reflects a persistent structural gender imbalance within the industrial and energy sectors and underscores the importance of more proactive efforts by organisers to ensure balanced representation in future events.  

The central theme: the CO₂ Infrastructure & Markets Regulation 

The most prominent issue throughout the event was the details of the upcoming CO₂ Infrastructure and Markets Regulation. The Forum seemingly served as a tool for gathering stakeholder input for the Regulation, currently open for consultation until 9 January 2026 and expected to be proposed in Q2 of 2026. Across panels, industry voices repeatedly called for clear, harmonised rules to enable cross-border interoperability of CO₂ transport and storage, including common CO₂ specifications and liability rules, while avoiding premature over-regulation that could stifle an emerging market, and legal certainty for investment.  

From Bellona’s perspective, the upcoming Regulation must go beyond general principles and provide clear, enforceable rules that enable a genuinely integrated European CO₂ network. While it is important to avoid overregulating a nascent market, this must be balanced with adequate safeguards, as the absence of such measures risks market failures that could hinder emission reductions in what is ultimately a natural monopoly. Ensuring transparent access and fair pricing will be essential to support efficient infrastructure development and enable rapid, cost-effective industrial decarbonisation in line with the EU’s climate objectives. 

First, the European Commission must expand and operationalise Article 21 of the EU CO₂ Storage Directive through a dedicated legislative instrument. This is necessary to harmonise third-party access rules for both CO₂ transport and storage infrastructure across Member States and to avoid fragmented national approaches that risk slowing down deployment. 

At national level, Member States must clearly designate the competent authorities responsible for overseeing third-party access to CO₂ pipeline infrastructure. These authorities should also be given an explicit mandate to review and approve transport and storage tariffs, ensuring fairness, transparency and non-discriminatory access. 

A pragmatic approach to unbundling is also required. CO₂ transport and storage infrastructure designed as multi-user systems should, by default, be subject to ownership unbundling. At the same time, point-to-point projects may remain vertically integrated where the risk of market distortion is demonstrably limited. 

To improve transparency and support efficient system design, network operators must be required to publish detailed CO₂ specifications, together with the scientific justification underpinning them. In parallel, Bellona supports the creation of an independent European CO₂ infrastructure planning body – potentially an ENTSO-C – with a mandate to develop EU-wide transport network plans under ACER oversight. 

Finally, the Regulation should explicitly enable public support for early-stage CO₂ infrastructure, including mechanisms to de-risk investments where transport capacity is not yet fully contracted. This will be essential to ensure that infrastructure deployment keeps pace with rapidly growing industrial demand. Read our recently published brief on what we consider the building blocks of a well-functioning CO₂ market here. 

The Elephant in the Room 

Underlying tensions went largely unaddressed on stage over a wave of legal challenges to the NZIA’s storage obligations. 15 oil and gas companies are reportedly suing the European Commission in an attempt to avoid delivering their CO₂ injection capacity contribution under Article 23 of the Net-Zero Industry Act [3]. This is especially concerning given that the Regulation was democratically adopted with broad political backing from the European Parliament and Member States, Europe risks shortage of CO₂ storage capacity, and many of these oil and gas producers have long portrayed themselves as champions of CCS deployment. 

Despite the lack of explicit discussion on the lawsuits, a clear and consistent message nonetheless emerged throughout the Forum. Emitters are ready to capture their CO₂ emissions, transport system operators are preparing to deploy CO₂ transport infrastructure, but for the technologies to deliver emission cuts, storage must also be deployed at pace. Currently more than 60 Mt per year of CO₂ capture capacity is under development across Europe, compared to only around 37 Mt per year of planned storage capacity, with less than 3 Mt currently under construction [4]. Unless this gap is urgently addressed, it risks becoming the single most significant barrier to scaling up CCS, jeopardizing the EU’s climate objectives. 

This is why it is essential that Article 23 of the NZIA is safeguarded and accompanied by strong enforcement measures in the form of penalties for non-compliance. Bellona will work actively next year to ensure that obligated oil and gas entities cannot avoid climate accountability and instead deliver their fair share of contributions. 

What’s in store for CCS and industrial decarbonisation in Europe next year? 

Looking to 2026, the year ahead will be decisive for maintaining momentum on CCS deployment and industrial decarbonisation in Europe, and keeping the 2030 objectives on track. Several key developments are expected to shape the policy and investment landscape.  

• NZIA enforcement takes centre stage. By mid-2026, penalties for non-compliance with the Net-Zero Industry Act are expected to be published. This will be a critical test of the Act’s credibility and its ability to translate binding targets into concrete action with regard to Article 23’s CO₂ storage obligations. 

• Publication of the CO₂ Infrastructure & Markets Regulation. The long-awaited Regulation setting the rules for CO₂ transport infrastructure and the market for technological CO₂ abatement is expected to be published following the conclusion of the public consultation. Its design will be central to determining whether the Union can build a coherent, interoperable CO₂ network and a well-functioning CO₂ market at the pace required to meet 2030 targets. 

• Reshaping carbon pricing incentives through ETS and CBAM. The continued phase-out of free allowances under the EU Emissions Trading System, alongside the gradual phase-in of the Carbon Border Adjustment Mechanism, will expectedly gradually reshape the economics of industrial decarbonisation. Together, these instruments are expected to strengthen incentives for investment in low-carbon production pathways, including CCS. 

• Final Investment Decisions on key CCS projects. Several CO₂ transport, storage and capture projects across Europe are expected to reach Final Investment Decision in 2026. These decisions will be crucial for translating policy commitments into infrastructure deployment and for determining whether the EU remains on track to deliver the required scale of CCS by 2030. 

Bellona’s recommendations for accelerating CCS deployment 

1. Adopt a strong and enforceable EU framework for CO₂ transport and storage infrastructure. This should include operationalising Article 21 of the CO₂ Storage Directive to harmonise third-party access across Member States, with clearly designated national authorities mandated to oversee access and approve transport and storage tariffs. The upcoming Regulation require unbundling for multi-user infrastructure while allowing point-to-point projects where market risks are limited. It should also mandate transparency through the publication of CO₂ quality specifications and support the creation of an independent EU-level CO₂ infrastructure planning function.  

2. Strengthen and extend public support for CCS deployment. Continued EU and national support – through grants, tax incentives, state-backed finance and Carbon Contracts for Difference – remains essential to de-risk CCS projects and unlock private investment in order to and until a functioning CO₂ market is established. The upcoming CO₂ Infrastructure & Markets Regulation must explicitly enable public support mechanisms to de-risk early-stage CO₂ transport and storage infrastructure where capacity is not yet fully contracted. 

3. Accelerate CO₂ storage development and permitting in line with NZIA obligations. The Net-Zero Industry Act sets a binding obligation on 44 oil and gas companies to deliver at least 50 Mt of annual CO₂ injection capacity by 2030. Meeting this obligation at scale will require coordinated action across all parties involved. Obligated entities must accelerate exploration and site characterisation activities, as well as the necessary investments, to bring new CO₂ storage sites to maturity. In parallel, Member States must enable faster project development by streamlining permitting procedures, strengthening administrative capacity, aligning national processes with NZIA timelines and requirements, while adopting strong penalties for non-compliance by obligated entities. In addition, the European Commission should support and oversee this process by facilitating access to geological data, promoting more harmonised approaches to storage permitting across the EU, and closely monitoring progress towards the 2030 storage target. 

4. Advance EU coordination and market-building tools. The Commission should accelerate the delivery of the CO₂ Investment Atlas, CO₂ demand aggregation mechanisms and knowledge-sharing platforms, as outlined in its Industrial Carbon Management Strategy [5]. These tools are essential to improve coordination, reduce uncertainty, and strengthen collaboration across the CCS value chain, supporting more efficient planning and derisking investment decisions. 

5. Engage local communities early in the planning process by mapping local sentiments and consulting local communities and ensuring that they receive tangible benefits from CCS projects, aligning with the principles of a just transition.  

References:

[1] European Commission (2025), 5^th Industrial Carbon Management Forum, available here. 

[2] European Commission (2025), Commission Decision (EU) 2025/1479 of 22 May 2025 specifying the pro rata contributions to the Union CO₂ injection capacity objective by 2030, available here.  

[3] Big Oil turns litigious in fight over EU’s carbon storage mandate | Euractiv 

[4] Fossil Fuel Giants Challenge EU CO2 Storage Obligations | Carbon Herlad 

[5] European Commission (2024) Communication on the Industrial Carbon Management Strategy, available here.