IOGP Europe’s response to CO₂ markets and infrastructure public consultation

IOGP Europe welcomes the European Commission’s consultation on the forthcoming proposal for CO₂ markets and infrastructure and submitted his response to the questionnaire along with an annex further elaborating on selected questions from the questionnaire. 

IOGP Europe advocates a principles-based and proportionate framework, avoiding premature or overly prescriptive regulation in a market that is still emerging. Regulatory measures should reflect different onshore and offshore transport realities, while preserving flexibility for project-specific solutions and new investments. 

Current barriers to CCS deployment are not driven by access rules, which already exist under EU law, but by slow permitting, legal and cross-border uncertainty, limited storage availability in some Member States, and high upfront investment risks. EU action should therefore focus on enabling conditions, including streamlined permitting, legal clarity, and targeted early-stage support. 

Planning and coordination can support visibility and cooperation, but infrastructure development will ultimately be driven by market signals and contractual arrangements, including with EEA partners such as Norway. 

IOGP Europe supports a gradual and evidence-based regulatory approach to tariffs, access, CO₂ quality, and infrastructure repurposing, allowing commercially negotiated solutions in the early phase and reserving more detailed regulation for when the market has matured and operational experience justifies it. 

IOGP Europe believes that Europe’s CO₂ markets and infrastructure can only scale at the pace required if the EU framework remains flexible, proportionate, and investment-enabling. At this early stage, EU action should focus on removing legal and administrative barriers, supporting cross-border cooperation, and providing certainty for first movers, rather than imposing prescriptive market design rules.  

A gradual, evidence-based approach will ensure regulation evolves in step with market maturity, supports bankable projects, and delivers the CO₂ transport and storage capacity needed to meet Europe’s climate objectives.