EU Work Programme 2026: CO₂ Infrastructure Initiative Planned

Establishing an Internal Market for CO₂ Transport and Storage

The Commission plans to present a legislative proposal for the "Development of the CO₂ transportation infrastructure and markets" in the third quarter of 2026. The Directorate-General for Energy has already launched a public consultation on this topic, which aims to assess the current regulatory framework for the entire CO₂ value chain and identify potential solutions to address regulatory gaps.

Cross-Border CO₂ Transport and Market Integration

The current consultation paper outlines measures to remove regulatory barriers to cross-border CO₂ transport, including ensuring cross-border interoperability and uniform CO₂ standards to prevent market fragmentation. Challenges arise in particular from international treaties such as the London Protocol, which legitimately aims to protect the marine environment but, in its current form, creates regulatory barriers to geological CO₂ storage in the seabed. An amendment to the Protocol intended to facilitate cross-border CO₂ transport for geological storage purposes – whilst safeguarding environmental protection interests – has yet to enter into force.

Competitive CO₂ Value Chain

The Directorate-General for Energy outlines crucial regulatory aspects in its consultation paper that could be included in the CO₂ legislation planned for 2026:

• third-party access to CO₂ transport and storage infrastructure facilities;
• infrastructure financing through regulated tariff structures and network charges;
• roles, activities, and ownership structures for infrastructure operators to prevent conflicts of interest;
• removal of barriers to repurposing existing infrastructure for CO₂ transport and storage;
• authorisation frameworks for CO₂ transport and storage facilities;
• governance structures and independent regulatory oversight of CO₂ markets.

In the interests of relevant stakeholders in the industry and energy sectors, careful attention should be paid to ensuring that the Commission adopts a balanced regulatory approach for the CO₂ sector. Such an approach should provide effective investment incentives and long-term financing certainty. Strict unbundling requirements and inflexible network access and tariff rules warrant critical examination. The guiding principle should be that regulation applies only where strictly necessary to address foreseeable market distortions.

Conclusion and Outlook

The EU Work Programme 2026 establishes the foundation for developing a European CO₂ internal market and CO₂ transportation infrastructure. The legislative proposal scheduled for the third quarter of 2026 will, for the first time, create a comprehensive legal framework governing CO₂ transport and markets.