IOGP Europe call for simplification of EU permitting

The EU’s ability to achieve its industrial decarbonization and energy transition objectives hinges on the effectiveness of its permitting systems. However, current frameworks are too often fragmented, slow, and ill-adapted to the complexity, scale, and urgency of today’s strategic infrastructure needs. Lengthy and unpredictable permitting procedures undermine investor confidence, delay the deployment of green and low carbon technologies (including CCS and hydrogen) and place the EU’s climate and competitiveness targets at risk.

Permitting plays a critical role in Europe’s industrial competitiveness, energy security and decarbonization goals. Yet across the EU, permitting regimes remain misaligned with the pace and complexity of the clean energy and industrial transition. As a result, projects essential to decarbonization and secure energy supply are routinely delayed, increasing costs, weakening supply chain resilience and eroding investor confidence. The consequences go beyond missed climate targets. Europe’s ability to attract and retain clean industrial investment is also at stake. The US and China have introduced faster, more predictable frameworks to accelerate deployment. Unless Europe treats permitting reform as both an economic and strategic imperative, it risks falling behind global competitors.

Permitting must therefore be treated as a strategic enabler, backed by coherent legislation, streamlined procedures, and strong institutional capacity at all levels. This is essential not only for meeting the EU’s energy and climate objectives, but also for delivering the Net Zero Industry Act (NZIA) and ensuring long-term energy security and industrial resilience in an increasingly volatile global landscape.

IOGP Europe puts forward a set of concrete recommendations aimed at delivering faster, more predictable, and fit-for-purpose permitting systems. These include harmonizing administrative procedures, strengthening capacity and resourcing, deploying digital tools intelligently, and introducing tailored frameworks for strategic sectors such as CCS, hydrogen, and industrial clusters.

The following summarized recommendations are designed to support the European Commission, Member States, and permitting authorities in accelerating permitting reform, while maintaining high standards of environmental protection and public engagement:

1. Streamline and harmonize administrative permitting processes across Member States, to reduce delays duplications and legal uncertainty
2. Clarify and align legal obligations across directives to reduce litigation risks and improve consistency, especially for projects spanning over several jurisdictions
3. Establish legally enforceable time limits for permit granting with tracking and recourse through national courts, drawing on best practices from other jurisdictions.
4. Launch wider introduction of one-stop shops, and mandate national-level interoperability, complemented by risk-based information requirements
5. Pair digitalization with procedural discipline, risk-based data requirements and minimum EU-wide standards for interoperability
6. Ensure sufficient resources at the national level through existing EU financing instruments and require Member States to submit annual staffing and capacity reports
7. Adopt a horizontal permitting Omnibus to harmonize implementation and reduce legal conflict between directives
8. Ensure consistent transposition of EU permitting legislation by guiding Member States through structured exchanges and best practice frameworks
9. Support the rollout of digital permitting procedures by 2035, in line with Industrial Emissions Directive (IED) Article 5 and avoid gold plating, misinterpretation or unnecessary administrative burden through the pancaking of administrative obligations
10. Integrate the principle of ‘tacit approval’ into EU legislations, to create accountability and time discipline in permitting procedures, with safeguards for environmental protection. Encourage Member States to establish ‘tacit approval’ mechanisms in national permitting systems.
11. Introduce fit-for-purpose permitting regimes for strategic sectors, including cluster-level permitting options for infrastructure designated under the NZIA, Critical Raw Materials Act (CRMA) and other relevant frameworks
12. Promote political continuity through cross-party agreements and long-term planning tools to ensure permit durability

For additional information on this topic, you can access the report from our 2024 Permitting Workshop organized with the European Commission.

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