This assessment examines how the eleven Member States hosting obligated oil and gas entities are implementing Article 23(13) of the NZIA, three months after the 30 June 2026 deadline. It looks at progress in establishing penalties, emerging approaches to penalty design, and the legal and institutional factors shaping enforcement.

Implementation of Article 23(13) remains incomplete across the eleven Member States hosting obligated entities, none of which had an enforceable penalty regime in place by the 30 June 2026 deadline. Since then, Member States have progressed at different speeds and taken different approaches to penalty design. While some are still determining how to integrate the obligation into their national legal frameworks, others have moved towards concrete penalty regimes, with significant differences emerging in how penalties would be calculated.

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• Article 23 penalty regimes across eleven Member States: A comparative analysis (pdf)