Tracking Article 23 of the Net Zero Industry Act
Article 23 Watch provides an evidence based overview of progress by obligated entities and Member States under the Net Zero Industry Act.
What is Article 23?
Article 23 establishes a first-of-a-kind obligation on oil and gas producers in the European Union to contribute to the development of CO2 injection capacity. Its implementation will shape how accountability, storage development, and regulatory oversight evolve in practice.
Obligated entity tracker
Explore our tracker on progress by the 44 oil and gas entities under Article 23.
Member State tracker
Explore how Member States are approaching implementation.
Publications
Read reports, briefings, and analysis on Article 23 and evolving topics.
Article 23 Watch
Article 23 Watch is a joint initiative of Carbon Balance Initiative, Clean Air Task Force, and Bellona Europa. The project monitors the implementation of Article 23 of the Net Zero Industry Act, with a focus on transparency, accountability, and emerging policy and legal developments.
Why did we start this project?
Here’s what our project team says about why we started the Article 23 Watch project. Contact us to learn more.
“The CCS market is currently defined by a lack of cohesion, as well as a power imbalance across the value chain. This project seeks to ensure that we address the “chicken and egg” paradox. History has shown that profit-seeking businesses are rarely well-suited to regulate themselves, this project will operate as a watchdog, holding oil and gas producers accountable for their commitment under the NZIA, and beyond”
Lina Strandvåg Nagell
“Article 23 embeds the much-needed accountability to ensure oil and gas producers contribute to developing geological CO₂ injection capacity. However, its success depends on rigorous enforcement and a transparent implementation framework that prevents loopholes and ensures compliance. This project will provide the data, analysis and oversight to ensure Article 23 delivers“
Codie Rossi
“Article 23 marks an important first step, but Europe cannot afford short-term thinking. Achieving the EU’s climate goals requires a long-term, durable, and self-sustaining storage market that ensures accountability well beyond 2030. That’s why we are collaborating with CATF and Bellona to shape the policies and enforcement mechanisms needed to secure long-term geological CO₂ storage capacity and drive real impact“
Ingrid Udd Sundvor
Obligated entity tracker
This tracker analyses the progress of obligated oil and gas producers in delivering CO₂ injection capacity under Article 23 of the Net Zero Industry Act. Drawing on publicly available project data, it assesses announced storage developments against each entity’s individual obligation, highlighting areas of alignment, shortfall, and uncertainty.
It is designed to support evidence-based monitoring of implementation and to provide insights into the evolving European CO₂ storage market.