Article 23 of the Net Zero Industry Act (NZIA) establishes an EU-wide obligation for oil and gas producers: by 2030, 44 obligated entities must develop 50 million tonnes of CO₂ injection capacity per year. While the obligation rests on oil and gas producers, Member State governments play a central role in enabling and enforcing its delivery. They are responsible for ensuring that the national legal, administrative, and regulatory frameworks required under the NZIA are in place so that obligated entities can develop injection capacity on time. This includes establishing single points of contact for project promoters, providing a centralised online permitting portal, offering administrative support, granting priority status to strategic projects, applying streamlined permitting deadlines for CO₂ storage sites, ensuring transparent publication of geological data and annual reports, removing barriers to access to CO₂ transport infrastructure, and adopting penalties for non-compliance (Articles 6, 7, 8, 15, 16, 21, 22 and 23 of the NZIA).

The 50 MtCO₂ annual injection capacity obligation is divided among 11 Member States in which the obligated oil and gas entities are registered: Ireland, France, the Netherlands, Italy, Austria, Germany, Denmark, Croatia, Hungary, Poland, and Romania. These countries are directly responsible for enforcing Article 23, and their progress towards complying with the NZIA’s requirements for Member State governments also determines whether the EU can meet its 2030 injection-capacity target. They’re also responsible for putting in place the enabling measures required under the NZIA.

This first edition of the report focuses on these 11 Member States because they hold both enabling and enforcement responsibilities. However, all EU Member States must comply with the NZIA’s enabling requirements, regardless of whether obligated entities are registered in their territory.

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