A new monitoring initiative is aiming to track how effectively Europe’s oil and gas sector delivers on its obligations to build carbon storage capacity under the EU’s Net Zero Industry Act. Known as Article 23 Watch, the project provides an evidence-based overview of how both companies and Member States are progressing in implementing one of the law’s most consequential provisions.
Article 23 requires oil and gas producers operating in the EU to contribute to the development of CO2 injection capacity, helping ensure sufficient storage is available to meet the bloc’s 2030 climate targets.
The initiative is led by Carbon Balance Initiative, Clean Air Task Force, and Bellona Europa, and is focused on improving transparency, accountability, and oversight in what remains an emerging carbon management market.
Addressing the CCS “chicken-and-egg” problem
Article 23 is designed to tackle a longstanding barrier to carbon capture and storage (CCS) deployment: the lack of coordination between capture projects and storage infrastructure. Without certainty that storage capacity will be available, investment in carbon capture has often stalled, while storage developers have faced uncertainty over future demand.
By placing a formal obligation on producers to help develop storage capacity, the regulation aims to align incentives across the value chain. However, its effectiveness will depend on how consistently it is implemented and enforced across Member States.
Article 23 Watch seeks to play a role in that process by analysing publicly available data on CO2 storage projects and comparing it against individual company obligations.
Relevant: CATF Roadmap Charts Cost-Effective CCS Deployment For Central and Eastern Europe
The platform highlights gaps between announced developments and required capacity, offering insight into areas where progress may be falling short.
The initiative also reflects broader concerns around governance in the CCS sector. With significant reliance on private sector investment, questions remain about how to ensure compliance, avoid loopholes, and maintain long-term accountability beyond 2030.
As Europe works to scale up carbon capture and storage as part of its decarbonisation strategy, tools like Article 23 Watch point to a growing emphasis on data transparency and independent oversight, seen as critical for building a functional and credible CO2 storage market.
Read more: Beyond the Bottleneck: CaptureMap Reveals Europe’s Real CCUS Challenge
