IOGP position on capital requirements
This document provides IOGP's position on capital requirements. This paper was drafted in response to the revision of the Capital Requirements Regulation (CRR), part of the review of EU banking rules.
Context
The oil and gas industry supports a stable global financial system. Many banks have set ambitions to help achieve net-zero emissions by 2050 by aligning their lending and investment portfolios.
Many of our Members have published or will publish transition plans in line with EU disclosure requirements. These plans will be designed to ensure that the business model and strategy of the undertaking are compatible with the transition to a sustainable economy, and with the limiting of the temperature increase to 1.5°C above pre-industrial levels in line with the Paris Agreement, in compliance with the requirements of the Corporate Sustainable Reporting Directive (CSRD).
Consequently, the strategies and business models of oil and gas companies are evolving. Our industry is working towards long-term solutions, in particular, Carbon Capture Use and Storage (CCUS), renewable energies, and hydrogen solutions to help the EU achieve its climate neutrality target by 2050. Significant investments will be necessary to support decarbonization and transition activities while ensuring the security of energy supplies.
Key Recommendations
- Requirements imposed on existing or new oil and gas investments should not prevent secure and safe energy supply to Europe: a balanced approach between urgent short-term needs and long-term goals is needed
- Any policy intervention related to capital requirements should be founded on robust evidence, such as evidence derived from climate risk stress testing to determine the true prudential risk, in order to transition to a net zero economy while ensuring sustainable economic growth and competitiveness within the EU
- Increased capital requirements for oil and gas activities might affect the level playing field in the banking sector since EU banks, subject to more stringent rules, might lose access to profitable investment opportunities in the energy sector. Therefore, a careful and balanced approach should be taken to ensure a level playing field both within and outside the EU
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IOGP Europe calls for simplification of the hydrogen regulatory framework through the Omnibus Package
IOGP Europe response to the EU Taxonomy – review of Climate and Environmental Delegated Acts consultation
Recommendations on the proposed new EU funding architecture under the MFF (2028-2034)
Joint industry letter ahead of the plenary vote on the First Omnibus Simplification Package
IOGP Europe’s response to the call for evidence on the General Block Exemption Regulation (GBER)
Amended ESRS Exposure Draft July 2025 Public Consultation Survey
Ten action points for a Hydrogen Grids Strategy
IOGP Europe’s response to Draft T&Cs for the H2 Bank third auction
The Mediterranean: an energy and decarbonization opportunity for Europe
IOGP Europe views on the Grids Package
Updated European CO₂ Storage Projects Map
IOGP Europe response to consultation on the Industrial Decarbonisation Accelerator Act (IDAA) and call for evidence
Joint statement: Urgent need for European Commission to correct course on the draft Delegated Regulation on Low Carbon Fuels
IOGP Europe response to ESMA Consultation on the draft technical standards under the ESG Ratings Regulation
The upcoming Grids Package: a critical opportunity not to be missed for the deployment of a European hydrogen infrastructure
Omnibus Simplification Package: Open Letter with Eurogas and FuelsEurope
Unlocking the Black Sea’s Strategic Energy Potential
EU Hydrogen Strategy needs a fundamental reset
Simplification Omnibus Package: towards a proportionate, coherent and efficient sustainability framework for European competitiveness
Response to the European Commission’s consultation on the draft Clean Industrial Deal State Aid Framework (CISAF)
Public consultation on inter-temporal cost allocation mechanisms (ICA) for financing hydrogen infrastructure
Joint Position Paper – Extending the ‘Stop-the-Clock’ Initiative to Wave 1 Companies
Joint Statement: Call for action- Urgent need to recognise third country exports of gaseous fuels under the Union Database
Advancing a Competitive, Resilient, and Integrated Energy Market
IOGP Europe Response to the Consultation on the Review of the Taxonomy Climate Delegated Act
Joint Statement: Reality Check for European Hydrogen Policy to Adjust the Course
IOGP Europe recommendations for the Omnibus proposal
Recommendations for a Clean Industrial Deal
The Case for a European CCS Bank
Joint Trade Association Statement: Towards EU due diligence that works for all
The Joint Statement on the Low-Carbon Fuels certification draft Delegated Act
IOGP response to the public consultation on the draft Methodology to determine the greenhouse gas (GHG) emission savings of low-carbon fuels
Joint EGEC-IOGP Europe recommendations: Accelerating the deployment of Geothermal in Europe
IOGP Europe key principles on a future regulatory framework for CO2 transport infrastructure
Joint Statement on the Low-Carbon Fuels certification Delegated Act
GasNaturally Letter to Competitiveness Council 23 May 2024
IOGP Europe recommendations on the Delegated Act specifying a methodology for assessing GHG emissions savings from low-carbon fuels and low-carbon hydrogen
EU Taxonomy Stakeholder Request Mechanism
IOGP consultation response to draft EFRAG Value Chain Implementation Guidance (VCIG)
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IOGP consultation response: Rationalisation of reporting requirements
IOGP position paper on the European Commission’s public consultation on the EU climate target for 2040
Joint industry statement on the EU Taxonomy
IOGP Europe views on the EU corporate sustainability reporting framework
IOGP input on the EU Commission’s public consultation on the EU Taxonomy Delegated Acts
IOGP response on Competitive Bidding schemes for hydrogen under the Innovation Fund
IOGP response on revamping the Strategic Energy Technology (SET) Plan
IOGP position on the Corporate Sustainability Due Diligence Directive (CSDDD)
IOGP response to the public consultation on the Hydrogen and Decarbonized Gas Market package
IOGP comments to R. W. Howarth and M. Z. Jacobson (2021): How Green is Blue Hydrogen?
IOGP response to the public consultation on the Renewable Energy Directive (RED) proposal
IOGP response to the public consultation on the Energy Efficiency Directive (EED) proposal
IOGP feedback on the Platform on Sustainable Finance’s draft report on preliminary recommendations for technical screening criteria for the EU taxonomy
IOGP response to the public consultation on the FuelEU Maritime proposal
IOGP feedback on the Platform on Sustainable Finance’s draft report on social taxonomy
IOGP feedback on the Platform on Sustainable Finance’s draft proposal for an extended taxonomy to support economic transition
IOGP response to public consultation on the revised Climate, Energy and Environmental Aid Guidelines (CEEAG)
IOGP Paper on metric to use for 2030 targets
IOGP input to the consultation on the Hydrogen and Gas Market Decarbonization Package
Response to consultation on costs of implementing MRV regulation based on OGMP
IOGP position on the European Commission proposal on the update of the Corporate Sustainability Reporting Directive
FuelsEurope and IOGP position on the Draft Delegated Regulation on taxonomy related disclosures by undertakings reporting non-financial information
IOGP response to the roadmap on the modification of the General Block Exemption Regulation (GBER)
IOGP response to the roadmap and inception impact assessment concerning revision of the 3rd Gas Package
Response to consultation on proposal for an Initiative on Sustainable Corporate Governance
Consultation on the Review and the Revision of Energy Efficiency Directive
IOGP response to consultation on the revision of the Guidelines on State aid for environmental protection and energy (EEAG)
Response form for the Consultation Paper on the Draft advice to European Commission under Article 8 of the Taxonomy Regulation
IOGP input to the Commission’s Delegated Regulation establishing the technical screening criteria for economic activities contributing substantially to climate change mitigation or climate change adaptation
IOGP written input to the consultation “Maritime sector – a green post-COVID future”
IOGP views on competition policy supporting the European Green Deal
IOGP statement on the European Commission’s 2030 Climate Target Plan
What’s Right? What’s Wrong? IOGP comments on the ‘EU Strategy for Energy System Integration’ and ‘A hydrogen strategy for a climate neutral Europe’
IOGP written input to the consultation “2030 Climate Target Plan”
IOGP response to the inception impact assessment concerning the revision of the 2018 Renewable Energy Directive (REDII)
IOGP input to the public consultation for the FuelEU Maritime – Green Maritime Space Initiative
IOGP input to the IIA on the EC’s Delegated Regulation on taxonomy-related disclosures by undertakings reporting non-financial information
IOGP response to the consultation on ESG disclosures under Regulation (EU) 2019/2088
IOGP response to consultation on the renewed Sustainable Finance strategy
IOGP response to the public consultation on the revision of Regulation (EU) 347/2013 on guidelines for TEN-E Regulation
IOGP response to targeted consultation on the revision of Regulation (EU) 347/2013 on guidelines for TEN-E Regulation
IOGP input to the Roadmap on the EU Smart System Integration
IOGP input to the Roadmap on the EU strategy on hydrogen in Europe
IOGP feedback to the Combined Evaluation Roadmap/Inception Impact Assessment on the revision of Regulation (EU) 347/2013 on guidelines for TEN-E
IOGP response to the public consultation on the revision of the NFRD
Sustainability reporting guidance for the oil and gas industry
IOGP feedback to the roadmap for a Renovation Wave initiative for public and private buildings
IOGP input to the forthcoming EU Strategy for Energy System Integration
IOGP response to the EIB Group’s Climate Bank Roadmap 2021-2025
Input to the inception impact assessment on the FuelEU Maritime
IOGP Initial Feedback to the Taxonomy: Final report of the Technical Expert Group on Sustainable Finance
IOGP feedback to the proposed European Climate Law
Feedback to the impact inception assessment “2030 Climate Target Plan”
Response to the inception impact assessment “Commission Delegated Regulation on a climate change mitigation and adaptation taxonomy”
IOGP input to the Impact Inception Assessment on the Revision of the NFRD
IOGP assessment of National Energy and Climate Plans
Scaling up Hydrogen in Europe
Hydrogen for Europe Pre-study – Key findings
IOGP assessment of draft National Energy and Climate Plans
Call for feedback on TEG report on EU Taxonomy
Hydrogen for Europe
IOGP response to the European Commission’s package on sustainable finance Call for a “Talanoa Platform” to guarantee a smart, inclusive and technology-neutral taxonomy
Press Release: European Parliament backs meaningful simplification of sustainability rules
New Pact for the Mediterranean: an opportunity to foster the region’s energy integration
Clean Industrial Deal – How to reconcile climate ambition with industrial resilience?
EU Low-Carbon Hydrogen production rules are not the signal investors were waiting for
Press release: 2040 Climate trajectory requires urgent action on policy enablers
Press release: State Aid Framework for Clean Industrial Deal marks a turn towards pragmatic decarbonization
Press release: Low-carbon fuels methodology envisaged by the Commission will block key hydrogen production pathways
Draghi Report: a pragmatic pathway to Competitiveness, Sustainability, and Resilience
IOGP Europe joined BusinessEurope in industrial permitting task force
IOGP Europe signs the Antwerp Declaration
Letter: IOGP Europe recommendations on the Hydrogen and Decarbonized Gas Market Package
Letter: The EU’s Corporate Sustainability Due Diligence Directive (CSDDD) – IOGP Europe and FuelsEurope recommendations in view of the trialogue negotiations
Letter: Open, inclusive, and pragmatic Green Deal Industrial Plan for Europe
Balance, strength and fairness: building blocks for a stronger Union
REPowerEU Plan: domestic gas production deserves stronger role alongside imports and renewables in enhancing EU energy resilience
Re-Powering the EU by protecting well-functioning markets, enhancing strategic partnerships and boosting domestic production
Inclusion of gas in the Taxonomy Regulation supports EU ambition to reach climate neutrality by 2050
Gas market reform marks a step change in EU approach to the transition
New Re-Stream study assesses the feasibility of transport of hydrogen and CO2 in European gas and oil infrastructure
More inclusion needed to be fit for 55
Letter: Call for a technology-inclusive revision of the TEN-E Regulation
“Hydrogen for Europe” study launch
Towards greater hydrogen production capacity in Europe
Letter: IOGP input on the European Commission’s consultation on the priority list for the development of gas network codes and guidelines for 2021 (and beyond)
Council’s inclusive approach to hydrogen sends strong signal ahead of key legislative year
EU Methane Strategy sets the right sequence to tackle the challenge
Sustainable Finance Webinars
EU’s hydrogen and energy system vision can only succeed with a more balanced, inclusive approach
Wide industry coalition call for a Hydrogen Strategy inclusive of all clean hydrogen pathways
Manifesto: Oil & Gas Industry Solutions Towards 2030 and 2050
IOGP Statement on the EU Recovery Plan
Climate change, purpose & doing the right thing: lessons from COVID-19
Guidelines for Methane Emissions target setting
Hydrogen for Europe: 1st Working Group Meeting
IOGP supports the EU’s objective of climate neutrality by 2050
SPE Europe Energy Conference
Rebalancing Europe’s natural gas supplies – Learnings, future needs, and policy implications
Scaling up the energy transition whilst securing a stable suppy
The Europe CCUS & Hydrogen Decarbonisation Summit
Re-Stream Study Launch Event
Hydrogen4EU Launch Event
Sustainable finance: investor, oil and gas sector and global perspectives
Carbon Management Webinars
Sustainable finance: non-financial disclosure for the oil and gas sector and EU taxonomy in practice