Project

Article 23 Project: Strengthening EU’s oil and gas accountability for CO₂ storage

Article 23 is a joint project by Clean Air Task Force (CATF), Carbon Balance Initiative (CB), and Bellona Europa, to support and assess the effective implementation of Article 23 of the European Union’s (EU) Net Zero Industry Act (NZIA). This initiative comes at a pivotal moment as the EU seeks to balance industrial competitiveness, energy security, and decarbonisation on the path to its 2050 climate goals. 

As the first regulation of its kind, the Net-Zero Industry Act (NZIA) Article 23 introduces a requirement for oil and gas producers to contribute to the development of CO2 injection capacity in the EU. This marks a shift in climate policy, embedding responsibility within the oil and gas sector to actively support CO2 storage. However, its success hinges on strong enforcement, transparent implementation, and coordination across borders and sectors.  

«For a successful green and just transition, we must ensure the decarbonization of harder- to-abate emissions through CCS. The CCS market is currently defined by a lack of cohesion, as well as a power imbalance across the value chain. This project seeks to ensure that we address the “chicken and egg” paradox, particularly by enforcing Article 23 in the NZIA to materialize into real injection capacity. History has shown that profit seeking businesses are rarely well-suited to regulate themselves, this project will operate as a watchdog, holding oil and gas producers accountable for their commitment under the NZIA, and beyond.»

Lina Strandvåg Nagell

Deputy Director & Head of Policy

This collaborative project will: 

  • Monitor compliance and enforcement trends across Member States through an Article 23 Implementation Tracker.  
  • Engage policymakers, industry, and civil society through policy briefs and stakeholder workshops. 
  • Develop a “2030-Ready” Policy Package with recommendations for strengthening oil and gas accountability frameworks post-2030. 
  • Raise public awareness and drive political momentum for CO₂ storage targets and corporate accountability across the EU. 

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