Introduction

Fossil fuels (coal - 8 billion tons, petroleum - 4 billion tons, and natural gas - 4 trillion cubic meters) account for the largest share of global primary energy consumption, representing 82% in 2021, a percentage that remains similar in recent years.^{^[1]} These fuels also account for much of the unsustainable anthropogenic activities that cause emissions of environmentally degrading substances, the so-called greenhouse gases (GHG).^{^[2]} Carbon dioxide (CO₂) is a common by-product of hydrocarbon combustion and can also be found in gas streams during petroleum activities. These emissions can occur anywhere along the oil and gas value chain, from extraction to refining, and are a global concern, affecting not only developing countries but also developed countries.

In light of increasing global consciousness of the challenges posed by climate change and environmental degradation,^{^[3]} there is a growing emphasis on developing effective mitigation strategies. Several scientific approaches are being explored to address these issues. While there is a strong push for the deployment of renewable energy technologies, nuclear power, and hydrogen as key strategies, these efforts collectively contribute to the broader goal of decarbonising the energy system. Although shifting to renewable energy is desirable, completely phasing out fossil fuels is, in the near future, practically impossible. This is particularly true for developing fossil-fuel-rich countries such as Nigeria, India, and Angola, among others. While the energy transition has been widely discussed, it was only recognized at COP28 in 2023 that transitioning away from fossil fuels does not mean the end of the fossil fuel era, but rather the beginning of the end.^{^[4]} To phase out fossil fuels from the global energy mix, there is a growing focus on technologies that minimize the carbon intensity of fossil fuel use. One option involves capturing and storing CO₂ emissions from petroleum operations. These technologies do not replace the overall strategy of avoiding or reducing greenhouse gas (GHG) emissions; rather, they serve as supplementary tools to help offset the environmental impact of prolonged fossil fuel use during the energy transition.^{^[5]}In addition, advances in scientific knowledge have led to the development of innovative technologies that have become mechanisms for mitigating the impact of GHG emissions associated with the use of fossil fuels.

Carbon Capture, Utilisation and Storage (CCUS) is a breakthrough technology for achieving this goal. CCUS projects are complex technological systems designed to capture CO₂ emissions from combustion or processing emitting facilities, preventing their release into the atmosphere. CCUS technologies use sophisticated air filtration systems to remove CO₂ directly from the atmosphere or store CO₂ captured from the fossil fuel industry. Direct air capture, or DAC, is the method of removing CO₂ from the surrounding air by isolating and capturing it. Given the pressing need for global climate action, it is important to focus on actively removing CO₂ from the atmosphere, alongside efforts to prevent and reduce CO₂ emissions.

This highlights the critical role of CCUS in achieving global climate change goals. Most advanced and industrialised countries are committed to utilising CCUS to meet their decarbonisation targets.

The implementation of CCUS projects is financially demanding. A recent study carried out by Independent Project Analysis concluded that it would require an estimated capital investment of US$500 million to build a model CCUS project, which performs the four components (capture and compression, transportation, utilization, and storage) of a CCUS, and it can capture up to 1 Mtpa of CO₂.^{^[6]} The capture and compression component of a CCUS project would demand three-quarters of this budget.^{^[7]} The cost implications and financing challenges associated with building CCUS projects have led to the resort to oil and gas infrastructures that are no longer in use (abandoned infrastructures) and otherwise ripe for decommissioning. The intention is to convert and repurpose abandoned oil and gas infrastructures towards CCUS technology development, which will mitigate the cost of CCUS facilities. However, decommissioning of oil and gas facilities remains a regulatory requirement and an anticipated expense in most jurisdictions, including Norway, Australia, and the UK. Nevertheless, the potential reuse of offshore oil and gas infrastructure for uses such as carbon capture and storage (CCS) has been studied as a way to reduce overall lifecycle costs.

Regulatory authorities often do not accept decommissioning delays based solely on hypothetical future CCS applications.^{^[8]} For example, in Norway, the cost of removing the Statfjord A platform from the continental shelf is expected to be NOK 3.5 billion (about €0.3 billion), and the decommissioning procedure is legally required regardless of any alternative uses. As a result, any proposal to repurpose infrastructure must be supported by concrete plans, regulatory approvals, and demonstrable feasibility, rather than being treated as a last-minute cost-cutting measure.^{^[9]}

This article explores the legal challenges related to suspending decommissioning and the repurposing of oil and gas infrastructure to support the development of a CCUS project.^{^[10]} While this innovative approach offers significant economic, technological, and environmental benefits, it also has legal and policy limitations. This paper is divided into six sections. Following this introduction section, section two examines the concept of CCUS and its environmental relevance. Section three highlights the constraints involved in implementing CCUS technologies. Section four discusses the decommissioning process and the potential of oil and gas facilities (designed for decommissioning) to support the development of CCUS technologies. Part five outlines the legal reforms needed to maximize the full value of CCUS development by reusing and repurposing decommissioned petroleum facilities. Section six is the concluding section of the paper.

1. Conception and Relevance of Carbon Capture, Utilisation and Storage Technology

The term Carbon Capture, Utilisation, and Storage (CCUS) describes a group of technologies that capture CO₂ emissions from industrial operations or fuel combustion. These technologies remove the CO₂, and either use the captured CO₂ for different purposes or store it in deep geological formations for a long period.^{^[11]} The International Energy Agency (IEA) claims that CCUS is an essential technology for reaching net-zero targets by removing CO₂ that is already in the atmosphere and reducing emissions in industries where decarbonisation is particularly difficult.^{^[12]} A typical CCUS project consists of four phases or components: CO₂ capture (including compression and dehydration), transportation, utilization, and storage.^{^[13]} By injecting the captured CO₂ into subterranean geological formations, CCUS aims to capture and eliminate CO₂ emissions generated during industrial operations.^{^[14]}

As of the end of 2023, there were approximately 395 commercial CCUS facilities globally, according to various industry sources, including the Global CCS Institute, the International Energy Agency (IEA), and the International Association of Oil and Gas Producers. Out of these, 43 are operational, 32 are at an advanced stage, 133 are under construction, and 187 are in the initial stage of development.^{^[15]} Out of the 395 CCUS facilities globally, 198 are located in North America, with 23 currently operating and 175 under development as of December 2023. At the time, only four European facilities were operational: Sleipner (Norway), Snøhvit (Norway), Quest (Canada), and Porthos (Netherlands, in early stages of operation).^{^[16]} The US has the highest number of CCUS projects globally.^{^[17]}

As of July 2023, operating CCUS installations have a total capture capacity of 49 Mtpa of CO₂. This statistic only includes facilities that are already operational, not projects that are under construction or in advanced stages of development.^{^[18]} This figure not only suggests the utility of CCUS facilities for carbon capture but also offers a glimpse of the potentially positive outcome of reduced greenhouse emissions should more CCUS facilities be developed. Indeed, apart from resorting to energy-efficient technology and transitioning to low-carbon fossil fuel energies, CCUS offers the best option for attaining the CO₂ emissions reduction target of the Paris Agreement.^{^[19]} Thus, increasing the number of CCUS facilities and their optimal operation would go a long way towards mitigating the impact of climate change worldwide.

The attainment of the post-2050 global climate goal involves not only reducing fossil fuel utilization but also removing GHG from the atmosphere through mechanisms such as deploying CCUS technologies.^{^[20]} To limit global warming to “1.5°C above pre-industrial levels”, as set out in the Paris Agreement, Parties will need to reduce annually GHG emissions into the atmosphere from the current 59.1 gigatons of CO₂ equivalent (GtCO₂e) to 25 GtCO₂e from 2019 to 2030.^{^[21]} Achieving net zero emissions by 2050 would require no less than a 60% reduction of GHG emissions.^{^[22]} CCUS can play a major role in achieving this objective.

Although the number of CCUS developments has increased over the years,^{^[23]} there is an urgent need to develop more facilities and ensure they are operating at their best to meet the global climate goal. It is estimated that 70-100 CCUS facilities will need to be built to achieve the global climate goal of net-zero carbon emissions by 2050.^{^[24]} This information has motivated several countries to intensify their efforts to advance the CCUS technology development to achieve this goal.^{^[25]}

2. Constraints to Deploy Carbon Capture, Utilisation and Storage Technology

The deployment of CCUS technologies would require identifying CO₂ sources and emissions clusters. One way to rank these clusters would be according to their CO₂ contribution. Consideration should be given to sectors with high CO₂ emissions, such as the transportation, cement, power, and petroleum industries.^{^[26]} Due to its significant CO₂ emissions, the petroleum industry should be prioritized for the initial deployment of CCUS technologies in nations with limited financial resources, such as Nigeria.

The construction of CCUS facilities raises several environmental concerns. Therefore, developers must consider key factors, including environmental considerations. The risk associated with the development of the CCUS project must be assessed, including the risk of CO₂leakage during transport and storage.^{^[27]} The need to guarantee the safety and efficiency of a CCUS infrastructure requires the implementation of monitoring and verification programs to improve the storage performance.^{^[28]} Developers must undertake an environmental impact assessment of the project and ensure that the relevant licenses and permits are obtained from the competent regulatory authorities.

As noted earlier in the introduction, this section will examine the challenges associated with the development of CCUS technologies. Amidst the various obstacles, this section will address two of these challenges: funding restrictions and infrastructural deficiencies.

2.1 Investment Restrictions

CCUS technology development is capital-intensive. The anticipated cost of building a basic CCUS project, including capture, transport, usage, and storage, could be as high as $500 million.^{^[29]} To achieve global net-zero emissions targets by 2050, it is estimated that at least US$120 billion in annual investment is required to effectively scale up CCUS technologies.^{^[30]} However, institutional reports indicate that less than half of that target had been met as of 2024. The EU presented a strategic investment vision for CCUS, including a €3 billion infrastructure investment fund.^{^[31]} Similarly, Denmark has committed €5 billion to targeted CCUS initiatives.^{^[32]} These initiatives demonstrate a growing commitment of advanced economies to accelerating CCUS implementation. Nonetheless, addressing the investment gap is a considerable problem, particularly in emerging countries where institutional capacity and access to private capital are restricted.^{^[33]}

To address the substantial investment gap in CCUS deployment, there is an urgent need for targeted government funding, strong policy frameworks, and market-based incentives to attract private sector participation.^{^[34]} Through programs such as tax credits and direct subsidies, government intervention has been crucial in advanced economies such as the US.^{^[35]} For example, according to Edward and Celia, the US offers a 50% funding subsidy for the construction of carbon pipelines, enabling the transportation of up to 19 million tonnes of captured carbon per year, with the possibility of increasing to 30 million tonnes if federal funding continues.^{^[36]} Additionally, the US Federal Investment Tax Credit and provincial laws in Canada, such as Alberta's Technology Innovation and Emissions Reduction Regulation, follow a similar approach.^{^[37]}

Meanwhile, the UK relies heavily on private-sector involvement through the Dispatchable Power Agreement (DPA), which offers a dual-payment model—availability payments and variable payments—to mitigate the risk of investing in low-carbon generation.^{^[38]}

However, this model of state-enabled, market-driven investment is more difficult to replicate in developing nations, where fiscal constraints and weaker institutional frameworks constrain both public and private investment. This raises serious concerns about international climate finance, technology transfer, and the role of multilateral institutions in mobilising capital for CCUS infrastructure in the Global South—a term commonly used to describe countries in Africa, Latin America, Asia, and Oceania with legacies of colonialism and economic marginalization, many of which are developing economies.^{^[39]} Without strong, tailored financial mechanisms and global cooperation, developing countries risk being excluded from the benefits of CCUS deployment, despite being among the most vulnerable to climate change impacts.^{^[40]}

Many developing nations face significant barriers to capital investment in the creation and operation of CCUS projects, as competing needs, such as healthcare, education, and infrastructure, typically take precedence. In Nigeria, for example, a single CCUS project is expected to cost around US$500 million (₦795 billion).^{^[41]} Although climate financing accounts for 3.65% of Nigeria's 2023 national budget (₦21.83 trillion), it faces structural obstacles in mobilization. These include restricted fiscal headroom, huge national debt loads, and insufficient access to concessional or blended financing. Additionally, legislative ambiguity and inadequate institutional structures discourage foreign cooperation and private-sector investment. According to recent studies, while necessary, technologies such as CCUS will remain out of reach for many regions vulnerable to climate impacts unless global climate finance mechanisms are restructured to serve developing countries better. ^{^[42]}

Another financing option would be to apply the polluter-pays principle to high-CO₂-emitting industries, such as petroleum, power, mining, and transport. The goal is to encourage industrial operators to either invest in carbon capture technologies to store their CO₂ emissions or face financial liabilities under a carbon tax if they do not switch to CCUS technologies to manage CO₂ emissions.^{^[43]} Under the US Federal Tax Credit Act, a tax credit is available to the carbon emissions industry for each metric ton of carbon captured.^{^[44]}

CCUS also represents an economic opportunity for its developers. Stored carbon can be converted into liquid fuels and chemicals by coupling it with green hydrogen.^{^[45]} Revenues generated from trading the converted CO₂ can be used to fund additional CCUS projects or offset the financial support needed for the initial project. In addition to advancing commercial feasibility, CO₂ monetisation of a CCUS project in Nigeria will assist petroleum sector operators in expanding their petroleum asset recovery capabilities.^{^[46]}

The provision of public financial support is governed by tight standards inside the EU's Internal Market, which comprises EU member states as well as European Economic Area (EEA) countries such as Liechtenstein, Iceland, and Norway. This is because unrestricted state aid can distort competition by favouring specific companies or industries, thereby undermining the fair operation of the single market. As a general rule, state assistance is forbidden by Article 107(1) of the Treaty on the Functioning of the EU. However, exceptions are permitted under Article 107(3) for aid that promotes goals such as environmental preservation, innovation, and the green transition. In this context, public investment in CCUS may be permissible, provided it complies with the criteria of EU competition law and is approved by the European Commission.^{^[47]}

2.2 Infrastructure Deficiency

CCUS consists of four main components: capture (including compression), transport, utilisation, and storage.^{^[48]} Each of these represents a distinct technological process that must be effectively integrated to achieve overall carbon reduction goals.^{^[49]} Infrastructure development is essential at every stage, from capturing and compressing CO₂ from emission sources to storing it safely and permanently.^{^[50]} Facilitating economies of scale and shared infrastructure through the creation of CO₂ hubs and industrial clusters greatly improves cost-effectiveness. Furthermore, when designing CCUS networks, it is crucial to consider the geographic proximity of suitable geological storage locations.^{^[51]}

The Longship Project in Norway is one of the most advanced examples of integrated CCUS infrastructure, which includes the Northern Lights CO₂ transport and storage network. This initiative addresses many of the logistical and technical issues commonly associated with CCUS deployment. It features a full-scale chain, including the CO₂ capture at industrial facilities, its transport by ship to an onshore terminal, and subsequent injection into subsea geological formations on the Norwegian continental shelf.^{^[52]} Notably, Northern Lights is designed to receive CO₂ from multiple European emitters, enabling cross-border transport and storage and demonstrating how regional cooperation can overcome infrastructure and regulatory challenges. Norway's Longship Project, which includes the Northern Lights CO₂ transport and storage network, exemplifies a modern integrated CCUS infrastructure. This effort has accomplished cross-border CO₂ transit and offshore storage, while also addressing logistical and technological problems related to CCUS implementation. The process involves capturing CO₂ from industrial facilities, transporting it to an onshore terminal, and then injecting it into subsea geological formations on the Norwegian continental shelf.

Multiple European emitters can contribute CO₂ to Northern Lights, enabling cross-border storage and transportation.^{^[53]} This illustrates how regional collaboration may assist in overcoming infrastructure and regulatory barriers. The first phase of infrastructure is expected to be completed in 2024, with operations set to begin in summer 2025. The project will then serve as a working model for commercial scalability, environmental risk management, and regulatory collaboration.^{^[54]} The project follows international legal standards, including the London Protocol for cross-border CO₂ transportation and storage. It is supported by clear regulations and major public investment from the Norwegian government.^{^[55]}

Longship therefore provides a model for overcoming legal, technological, and financial constraints to CCUS by careful policy design and public-private partnership.^{^[56]} The EU supports this model, recognising pipeline (and maritime) transport of CO₂ as the most technically and economically viable solution in many contexts.^{^[57]}

Efforts are underway to address infrastructure gaps in offshore and transboundary CO₂ transport systems, especially in regions without established networks. Norway's Longship Project, which involves transporting CO₂ by pipeline and ship from capture sites to the Northern Lights receiving terminal in Øygarden, is proving to be a viable and scalable model. This program exemplifies how collaborative, large-scale efforts may bridge infrastructure and regulatory barriers through implementation.^{^[58]} Rather than defining the problem as one of widespread absence, it is more appropriate to see it as a dynamic process in which developing gaps are progressively addressed through strategic planning, targeted investment, and international collaboration. This implies that, while gaps are inevitable in every new technological shift, the crucial question is whether they are being handled efficiently and effectively—and, in the case of the Longship Project, the answer appears to be affirmative.^{^[59]}

As for the US, the CO₂ storage program includes research and development, infrastructure, and global collaborations. The infrastructure aspect entails a CO₂ storage program focused on research and development to advance “geological CO₂ storage toward commercialization” and regional collaboration, which will consider differences in “geology, climate, population density, infrastructure, and socioeconomic development”.^{^[60]} While the US prefers onshore CCUS storage facilities, Norway favours offshore CCUS storage, even though both technologies are largely the same.^{^[61]} The main reason for Norway’s choice is that the country’s petroleum resources are located on the continental shelf. Actually, injecting CO₂ into depleted oil reservoirs can improve oil recovery, because the CO₂ will reduce oil viscosity, making it easier to displace the remaining oil in the reservoir that would not otherwise remain unrecovered.^{^[62]} The offshore storage facility option should ideally be located within the territorial sea, 12 nautical miles from the shoreline, to reduce the size of the CO₂transport facility required and associated costs.^{^[63]} The preferred style of CCUS storage facilities may well be influenced by what is seen as its comparative advantage.

3. Functionality of Abandoned Petroleum Infrastructure for Carbon Capture, Utilisation and Storage Technology Development

During the petroleum exploration process, drilling rigs and other equipment are brought into service at sites to ensure effective operations. Petroleum exploration facilities, such as any other mechanical equipment, have a productive life span. At the end of their life cycle, it is no longer commercially viable to continue operating them. In many cases, such facilities are abandoned by the operators. Given the environmental consequences of having unused petroleum facilities, it is standard practice for such facilities to be decommissioned by the operators, as required by petroleum regulations.^{^[64]}

The preceding section of this paper demonstrated the financial and infrastructural challenges associated with developing a CCUS technology. The cost of developing the CCUS facility and the lack of infrastructure have inspired the emergence of innovative solutions to address these challenges. One such innovation involves repurposing petroleum infrastructures earmarked for decommissioning and reuse for CCUS projects. Rather than dismantling the petroleum infrastructure or carrying out other decommissioning activities, it can be repurposed for CCUS projects. For example, oil pipelines that are no longer in use can be adapted to transport CO₂ to storage locations, provided that the necessary technical and legal requirements are met. The International Energy Agency suggests that existing oil and gas infrastructure, such as pipelines, can be converted for CO₂ transport, provided that material compatibility and pressure constraints are met.^{^[65]} Depleted oil reservoirs can also serve as geological storage sites where captured CO₂can be reinjected.^{^[66]}

The possibility of reusing petroleum infrastructure for CCUS has been verified, as according to the Scottish Affairs Committee, “[t]he ability to reuse petroleum infrastructure for CCUS projects reduces capital costs, accelerates deployment timeframes, and makes use of existing geological and technical data. Several studies have shown that repurposing offshore oil and gas infrastructure, including pipelines, wells, and platforms, is technically and economically possible under the correct conditions. In this regard, the Scottish Affairs Committee stated, "it would be regrettable if the potential for reused infrastructure for CCUS was lost due to a relatively short gap between infrastructure being decommissioned and CCUS becoming commercially viable."^{^[67]} While this comment emphasizes the importance of aligning CCUS preparedness with decommissioning timelines, it also highlights the broader significance of analyzing and preserving viable infrastructure for future CCUS initiatives before irreversible deconstruction occurs.^{^[68]} Rueda and Polesello also suggested using the same infrastructure currently used in the petroleum industry for CCUS.^{^[69]} According to one study, the UK has over 300 offshore oil platforms and 1,000 pipelines in the North Sea and Irish Sea that are close to decommissioning and could be used for CCUS projects.^{^[70]}

Some countries that are embarking on CCUS development have favoured the reuse and repurposing of oil and gas facilities for CCUS. In Scotland, one argument for deploying CCUS technology is the potential to reuse oil and gas infrastructure for CCUS. It is also argued that the UK’s depleted oil and gas fields provide an ideal environment for CO₂ storage.^{^[71]} For countries such as the UK, which has more than 78 gigatonnes of offshore geological storage capacity, this approach could help to bridge the infrastructure gap and avoid the cost of building new CCUS storage facilities.^{^[72]} As a result, it could also reduce the cost of decommissioning the abandoned oil and gas infrastructure. Another interesting case is the Porthos Project in the Netherlands, which has the potential to repurpose existing oil and gas infrastructure, including the P18-A offshore platform and depleted wells, for CO₂ injection operations. Porthos will take ownership of the P18-A platform and related fields in late 2025, with TAQA carrying out the conversion work on a contractual basis.^{^[73]} In turn, Professor Le Quéré also suggested that reusing a decommissioned petroleum pipeline for the Acorn CCUS project in Scotland would cost no more than £40 million, whereas building a new pipeline for CCUS transportation would cost around £200 million.^{^[74]} Repurposing petroleum infrastructure for CO₂ storage could reduce decommissioning costs. However, this possibility is highly dependent on the specific circumstances of each site, such as the integrity of legacy wells, the reservoir's suitability for permanent CO₂ storage, and the conditions of the current infrastructure. Repurposing may offer useful advantages such as access to pre-existing infrastructure, reservoir characterisation information, and operational expertise from prior field development, provided these requirements are satisfied. However, these benefits must be evaluated individually and cannot be taken for granted.^{^[75]}

4. Legal and Policy Implications of Decommissioning Suspension towards Carbon Capture, Utilisation and Storage Projects

As noted in the previous section, there is a growing trend to reuse and repurpose decommissioned oil and gas facilities for CCUS projects, given their environmental and socio-economic co-benefits. Despite its prospects, a wide range of regulatory gaps currently limit the large-scale reuse of decommissioned facilities for CCUS. This section discusses these regulatory gaps and proposes legal innovations to address them.

4.1 Need for a Comprehensive Regulatory Framework on Infrastructure Repurposing and Reuse

In most countries where the reuse of decommissioned facilities for CCUS is emerging, legal frameworks and policies have yet to be established to permit this practice. Since this innovation is still in its early stages, several countries are still assessing its viability, which explains the delays in its implementation. For example, the United Kingdom has lately made measures to build a more specific policy framework for the reuse of decommissioned assets.^{^[76]} The Energy Act of 2023 included measures to help the transition of oil and gas infrastructure to low-carbon applications, such as carbon capture and storage, closing previous regulatory loopholes.^{^[77]} In addition, the North Sea Transition Authority (NSTA) has created a Repurposing Screening Tool to help identify infrastructure that may be reused while adhering to environmental regulations, owner duties, and safety criteria.^{^[78]} These activities indicate that recent legislative and regulatory reforms in the UK now permit a more organized approach for the reuse of oil and gas infrastructure in CCUS projects.

Other countries still need to adopt regulations that allow repurposing oil and gas infrastructure for CCUS projects. For instance, Nigeria's decommissioning regulations primarily address the demolition of abandoned structures, offering few legal options for recycling or reuse. Section 232(7) of the Act requires leaseholders to completely remove onshore petroleum infrastructure at the end of its commercial cycle. In practice, the Nigerian Upstream Petroleum Regulatory Commission’s (NUPRC) Decommissioning and Abandonment Regulations 2023/2024 provide more detailed procedures and standards for the decommissioning, abandonment, and potential repurposing of petroleum infrastructure, thus supplementing this obligation.^{^[79]} This approach reflects a strict interpretation of decommissioning obligations. The Nigerian Upstream Petroleum Regulatory Commission (NUPRC) regulates offshore decommissioning and CO₂ storage under previous legislation such as the Petroleum Act (Cap. P10, Laws of the Federation of Nigeria). Before engaging in any repurposing or abandonment operations, operators must submit decommissioning and abandonment plans for assessment and approval under the NUPRC.^{^[80]}

In Australia, Section 574 of the Offshore Petroleum and Greenhouse Gas Storage Act 2006 mandates the full decommissioning of offshore infrastructure, unless specific exemptions are granted. While these legal frameworks underscore the broader regulatory conservatism regarding infrastructure reuse, some countries are beginning to explore tailored exemptions to enable repurposing for CCUS where it is technically and environmentally feasible.^{^[81]} The safe and efficient repurposing of decommissioned facilities for CCUS requires a well-defined legislative framework, especially with regard to standards, specifications, and environmental criteria.

For example, in the UK, the NSTA has developed a screening tool designed to ‘maximize the repurposing of oil and gas infrastructure for energy transition projects in the North Sea’.^{^[82]} This tool helps to identify infrastructure with repurposing potential while ensuring compliance with environmental standards, owner obligations, and safety requirements. As the repurposing of infrastructure for CCUS expands, both the UK and Nigeria, along with other jurisdictions, will need to develop legislation tailored to address the unique challenges of repurposing infrastructure, such as ensuring structural integrity, preventing CO₂ leakage, and mitigating environmental risks. In certain situations, operators would have to provide plans for repurposing infrastructure as part of the licensing procedure or within a predetermined time frame after decommissioning.

Adopting robust and comprehensive legal frameworks to foster CCUS adoption, as well as the reuse of decommissioned infrastructure for CCUS, can help reinforce its environmental and socio-economic value and provide guidelines for its safe, orderly, and sustainable deployment.

4.2 Need for Specific Fiscal Incentives on Reusing Decommissioned Facilities for CCUS

In jurisdictions with established regulatory guidelines for CCUS, there remains a need to provide fiscal incentives to foster social acceptance and investment in infrastructure repurposing and reuse initiatives.^{^[83]} Within the EU, for example, regulatory frameworks on CCUS are evolving rapidly. Directive 2009/31/EC on the geological storage of CO₂ created a foundational legal framework to support the green transition by facilitating the necessary regulations for geological CO₂ storage.^{^[84]}

This regulation took into consideration international agreements such as the OSPAR Convention and the London Protocol.^{^[85]} OSPAR Decision 2007/2, along with the 2007 revisions to Annexes II and III of the OSPAR Convention, permits the storage of CO₂ in undersea geological formations, provided that strict environmental protections are in place. The 2006 revision of the London Protocol permitted the storage of CO₂ streams in geological formations beneath the seabed. The EU's framework for geological CO₂ storage is based on these international legislative instruments.^{^[86]}

The directive covers site selection, exploration and storage licenses, operating requirements, post-closure duties, and third-party access to foster market competition.^{^[87]} Although this framework establishes the basic legislative parameters for CCUS, its implementation varies between EU member states.^{^[88]} For example, the United Kingdom and Norway have created more thorough and ambitious legislative structures customized to their specific circumstances. These frameworks clarify the implications for offshore CO₂ storage and decommissioning. Operators must demonstrate the long-term integrity and safety of offshore geological formations, accept liability for potential leaks, and ensure that decommissioning plans are integrated with storage site closure obligations. Decommissioning now includes the safe conversion, monitoring, and closure of offshore CO₂ storage installations, rather than merely the removal of petroleum facilities. The UK Energy Act 2023^{^[89]} mandates licensing for offshore CO₂ transport and storage, while Norway's CO₂ Storage Regulations require storage permit holders to integrate decommissioning with post-closure monitoring and liability.^{^[90]}

The UK's Carbon Capture and Storage (CCS) Directive and the Energy Act 2008 established the foundation for extensive support, including financial incentives and financing channels to encourage large-scale CCS projects. The Energy Act 2023 has expanded this framework by introducing a licensing regime for CO₂ transport and storage, strengthening decommissioning and post-closure obligations, and providing clearer financial support mechanisms to reduce the risk to private-sector investment. Together, these measures provide the UK with one of the most sophisticated legal and regulatory environments for CCUS deployment in Europe.^{^[91]}

Additionally, the UK's Environmental Protection Act 1990 and the Health and Safety Executive (HSE) Regulations further strengthen oversight and safety in CO₂ storage activities.^{^[92]} Similarly, Norway's regulatory framework under the Norwegian Petroleum Act and the CO₂ Storage Act is more extensive, incorporating stringent requirements for CO₂ storage, risk management, and environmental monitoring.^{^[93]} Norway’s regulatory framework has been instrumental in implementing the Longship Project, which integrates CCUS infrastructure for industrial emissions and offshore storage.^{^[94]}Despite these regulatory developments, dedicated deployment incentives to promote the reuse of decommissioned facilities for CCUS have yet to emerge fully across Europe.

Similarly, in Nigeria, as in other parts of Africa, a lack of specific fiscal policies to incentivise CCUS and the reuse and repurposing of infrastructure for CCUS has been identified as a key gap to its deployment and uptake.^{^[95]}

Furthermore, as is the case in many parts of the MENA region, countries may have development institutions that provide some level of financing for clean technology projects owned by nationals. However, accessing such financing remains a significant challenge for residents and non-nationals, particularly entrepreneurs from underrepresented groups, such as women, young people, immigrants, and the unemployed (source). Similarly, inadequate access to the expertise, resources, and knowledge needed to develop and deploy energy solutions continues to stifle innovation in some MENA countries.^{^[96]}Even where the necessary institutions exist, the lack of purposeful integration of energy citizenship metrics into policy and decision-making frequently restricts the availability and accessibility of financial incentives and assistance for a wide variety of energy entrepreneurs. Again, this disparity disproportionately impacts marginalized groups, such as women, young people, and immigrants, who face extra challenges in obtaining funding and technical resources for CCUS-related innovation.^{^[97]}

There is a need to move beyond merely legislating infrastructure repurposing for CCUS to providing actual deployment incentives that would make the initiative attractive from a cost and economic perspective. Such incentives could take the form of grants or other direct financial support to reduce the initial expenditure and burdens associated with infrastructure repurposing. Alternatively, investment tax credits or reversed taxes could provide equivalent funding for the upfront capital investment in repurposing infrastructure initiatives.^{^[98]} As regulatory authorities develop legal and policy frameworks for the infrastructure repurposing for CCUS, these regulatory developments should be underpinned by dedicated fiscal incentives to enhance their broad appeal from practical and economic perspectives. A good example is the EU Innovation Fund, which provides fiscal incentives for clean hydrogen infrastructure projects.^{^[99]} This type of Fund could be used to support infrastructure repurposing and reuse for CCUS across Europe, and it could inspire similar CCUS funds to be established at national and subnational levels in other regions and countries.

4.3 Clean Technology Entrepreneurship to Address Technology and Capacity Gaps

A key obstacle to the deployment of CCUS in many regions worldwide is the lack of technologies and infrastructure to support CCUS initiatives, including the repurposing of existing infrastructure for CCUS. For example, many of the developing countries in Africa, Asia and Latin America rank very low in terms of Technological Readiness Levels (TRLs ) for CCUS projects, which affects both the availability of technologies and the technical know-how required to implement existing infrastructure reuse initiatives.^{^[100]} In Nigeria, for example, the advanced sensing and real-time monitoring technologies needed to detect CO₂ migration or leakage in CCUS infrastructure are simply not available, resulting in near 100 percent dependence on technology transfer.^{^[101]} Studies have therefore highlighted the need for the rapid development of home-grown capacity and technologies needed to support the deployment of CCUS technologies, including those for infrastructure reuse initiatives.^{^[102]} There is a need to carefully address barriers to energy entrepreneurship in order to accelerate homegrown development of CCUS technologies and infrastructure reuse initiatives.^{^[103]}

In addition to providing financial and technical support for energy entrepreneurs to accelerate CCUS technologies and know-how, it is essential to address the barriers to the registration, formalisation, and commercialisation of CCUS innovations. For example, the infrastructure reuse and repurposing require regulatory permissions and the cooperation of a diverse range of stakeholders and institutions. Therefore, national governments must establish implementation structures that simplify the institutional requirements and approval processes for energy entrepreneurs. By way of example, lack of institutional coordination, bureaucracy, duplication of roles, and regulatory overlap remain key concerns that complicate the regulatory approval processes in many energy sectors in many parts of Africa and the Middle East.^{^[104]} To solve these inefficiencies, institutional harmonization must begin with changes to licensing procedures and standards for CCUS technology development and projects. Streamlining these regulations, as well as decreasing the time and cost of company registration and project licensing, can encourage more residents to pursue energy initiatives and endeavours.

Although administrative delays in company registration are not unique to the energy sector, the urgency of the energy transition and the need for climate change mitigation should motivate governments to take further measures to expedite licensing processes for CCUS projects and low-carbon technologies. In this sense, accelerator programs that assist energy entrepreneurs in building start-ups and transitioning from development to execution are therefore critical. Moreover, reforming project participation requirements that hinder the widest possible public engagement in energy access projects is also essential.^{^[105]} Plus, regulations, rules, and procedures that hinder private-sector participation or prohibit non-nationals from participating in energy projects should be revised to encourage broad participation and ensure equitable access to the resources required for infrastructure repurposing and reuse.^{^[106]}

Conclusion

This article examines the legal implications of reusing and repurposing decommissioned oil and gas infrastructure for the development of CCUS projects. It concludes that CCUS is a powerful tool for achieving the net-zero decarbonisation goals outlined in major international reports on climate change mitigation. However, the article notes that the development of CCUS faces strong financial and infrastructural constraints. To overcome these constraints, some countries have resorted to abandoning their decommissioning goals for petroleum infrastructures and redirecting their use to the development of CCUS projects. Nonetheless, it was found that only a few countries have established legislative and policy frameworks that would allow such a practice. The majority of decommissioning regulations do not permit the reuse of decommissioned petroleum facilities for CCUS, which may act as obstacles in this transition process.

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[1]Ali Akbari and others, ‘Characteristics, Emissions, Capture, Storage, and Utilization of Carbon Dioxide: A Comprehensive Review of Challenges and Technologies for Greenhouse Gas Mitigation’ (2025) Petroleum Research https://doi.org/10.1016/j.ptlrs.2025.07.001 accessed 27 July 2025.

[2]Ali Akbari and others, ‘Characteristics, Emissions, Capture, Storage, and Utilization of Carbon Dioxide: A Comprehensive Review of Challenges and Technologies for Greenhouse Gas Mitigation’ (2025) Petroleum Research https://doi.org/10.1016/j.ptlrs.2025.07.001 accessed 27 July 2025.

[3]This has been tagged “the tragedy of the commons” in Garret Hardin, ‘The Tragedy of the Commons’, (1968) 162 Science 1243-1248.

[4] UN. 2023. United Nations Framework Convention on Climate Change: Conference of the Parties serving as the meeting of the Parties to the Paris Agreement. (Document FCCC/PA/CMA/2023/L.17). United Arab Emirates, first global stocktake. p21.

[5] Yakubu Adekunle Alli and others, ‘Transforming Waste to Wealth: Harnessing Carbon Dioxide for Sustainable Solutions’ (2024) 17 Results in Surfaces and Interfaces 100321 https://doi.org/10.1016/j.rsurfi.2024.100321 accessed 27 July 2025.

[6] Ashling Neary, ‘CCUS Industry Insights Provide a Foundation for Future Projects’, (Independent Project Analysis, 2023) <https://www.ipaglobal.com/news/article/ccus-industry-insights-provide-a-foundation-for-future-projects/#:~:text=IPA's%20study%20found%20that%20a,1%20MTPA%20of%20CO₂.> accessed 27 March, 2025.

[7] ibid.

[8] Hope McLaughlin and others, ‘Carbon Capture Utilization and Storage in Review: Sociotechnical Implications for a Carbon Reliant World’ (2023) 177 Renewable and Sustainable Energy Reviews 113215 https://doi.org/10.1016/j.rser.2023.113215 accessed 27 July 2025.

[9] The impact assessment part of the Statfjord A decommissioning plan (in Norwegian) is available at https://cdn.equinor.com/files/h61q9gi9/global/d0ba856fd706712b2a03723f1a9fc17116cc62c2.pdf?avslutningplan-statfjord-a-konsekvensutredning-august-2018-equinor.pdf. Further information in English on the Norwegian decommissioning regimen can be found at https://www.norskpetroleum.no/en/developments-and-operations/cessation-and-decommissioning/.

[10] See: Eduardo G. Pereira, Alexandra Wawryk, Catherine Banet, Heike Trischmann, Keith Hall (eds.), Regulation of Decommissioning, Abandonment and Re-Use Initiatives in the Oil and Gas Industry: From Obligation to Opportunities (Kluwer International Law 2020); Ignacio Herrera Anchustegui, Madeline Taylor, Eduardo G. Pereira, Eddy Wifa, Offshore Energy Law: Challenges and Opportunities for Hydrocarbons and Renewables at Sea (Hart, 2025).

[11] The London School of Economics and Politics, ‘What is Carbon Capture, Usage and Storage (CCUS) and what Role can it Play in Tackling Climate Change?’ (2023) <https://www.lse.ac.uk/granthaminstitute/explainers/what-is-carbon-capture-and-storage-and-what-role-can-it-play-in-tackling-climate-change/> accessed 26 March, 2024.

[12] IEA, ‘Carbon Capture Utilisation and Storage - Energy System ’ (IEA) <https://www.iea.org/energy-system/carbon-capture-utilisation-and-storage> accessed 26 March, 2025.

[13] IEA, ‘Carbon Capture Utilisation and Storage - Energy System ’ (IEA) <https://www.iea.org/energy-system/carbon-capture-utilisation-and-storage> accessed 26 March, 2025.

[14] Josh Dickens and Buford B Pollett, ‘Carbon Dioxide Transport and Sequestration in the Submerged Lands of the United States Gulf of Mexico Region’, (2023) 21 (3) Oil, Gas & Energy Law Intelligence 1, 36.

[15] Statista, ‘Number of Commercial Carbon Capture and Storage (CCS) Facilities Worldwide as of 2024, by Status’, (2024) <https://www.statista.com/statistics/726624/large-scale-carbon-capture-and-storage-projects-worldwide-by-status/#:~:text=Global%20large%2Dscale%20carbon%20sequestration%20projects%202023%2C%20by%20status&text=There%20were%20approximately%20265%20projects,100%20were%20in%20early%20development.> accessed 26 March, 2024.

[16] Ian Tiseo, ‘Number and Status of Commercial CCS Facilities Worldwide 2024, by Region’, (2024) <https://www.statista.com/statistics/1308723/worldwide-ccs-facilities-by-region/> accessed 26 March, 2024.

[17] The London School of Economics and Politics, ‘What is Carbon Capture, Usage and Storage (CCUS) and what Role can it Play in Tackling Climate Change?’ (2023) <https://www.lse.ac.uk/granthaminstitute/explainers/what-is-carbon-capture-and-storage-and-what-role-can-it-play-in-tackling-climate-change/> accessed 26 March, 2024.

[18] Statista, ‘Capture capacity of operational commercial carbon capture and storage (CCS) facilities worldwide from 2010 to 2023’, <https://www.statista.com/statistics/726634/large-scale-carbon-capture-and-storage-projects-worldwide-capacity/> accessed 26 March 2025.

[19] Eduardo G Pereira, Alberto Fossa, Carlos Eduardo Pellegrino Cerri, Opeyemi Omotuyi, Hannah Hylton-Edwards, Edmilson Moutinho dos Santos, Alexandre Gallo, Cylon Liaw, and Bruna Toguedani, ‘Advancing Sustainability through Carbon Capture, Utilization and Storage (CCUS) Technologies: The Hydrogel Case Study’, (2023) 14 (1) The Journal of Sustainable Development, Law and Policy 218, 219.

[20] Ngozi C Ole, Opeyemi Y Omotuyi, Eti B Herbert and Dickson E Omukoro, ‘Environmental Laws and Enforcement: Prospects and Challenges’, in Ronnie Frazer-Williams, Mary B Ogundiran and Emmanuel I Unuabonah, ed. Environmental Pollution and Public Health: Case Studies on Air, Water and Soil from an Interdisciplinary Perspective (Elsevier, 2024) 305, 309.

[21] The Economist Group, ‘Zeroing in: Fostering Innovative Technologies for a Net-zero Future’, (2021)

<https://assets.ctfassets.net/bxxzjfpinfqw/3ofdWmcB5AwFieAYWWQfPz/72d35809a2fcf17a39510d3c38213d98/Economist_Impact_Invesco_Designed_report_01112021_disclosure_v2__1_.pdf > accessed 5 May 2025.

[22] Ibid.

[23] There has been over 44% within the past one year. See, Global CCS Institute, ‘Carbon Capture and Storage Experiencing Record Growth as Countries Strive to Meet Global Climate Goals’ (2022) <https://www.globalccsinstitute.com/news-media/press-room/media-releases/carbon-capture-and-storage-experiencing-record-growth-as-countries-strive-to-meet-global-climate-goals/> accessed 4 May, 2025.

[24]Global CCS Institute, ‘Global Status of CCS 2021’, <https://www.globalccsinstitute.com/wp-content/uploads/2021/10/2021-Global-Status-of-CCS-Report_Global_CCS_Institute.pdf> accessed 5 May, 2025.

[25]The Economist Group, ‘Zeroing in: Fostering Innovative Technologies for a Net-zero Future’, (2021)

<https://assets.ctfassets.net/bxxzjfpinfqw/3ofdWmcB5AwFieAYWWQfPz/72d35809a2fcf17a39510d3c38213d98/Economist_Impact_Invesco_Designed_report_01112021_disclosure_v2__1_.pdf > accessed 5 May, 2024.

[26]International Energy Agency, ‘Facilitating Nigeria’s Energy Transition through CCUS Development’, (2021) <https://iea.blob.core.windows.net/assets/a196066a-3225-42ab-b341-d432452058f0/IEAOVP_NigerianCCUS_Event_Summary_Final.pdf> accessed 27 March, 2025.

[27] Angelica Rutherford, ‘The Application of the Environment Act 2021 Principles to Carbon Capture and Storage’, (2022) 11 (15) Laws 1, 9 <https://doi.org/10.3390/laws11010015> accessed 6 April, 2024.

[28] Tom Mikunda, ‘CCUS Projects Network Outputs and Deliverables’, <https://ccuszen.eu/sites/default/files/CCUS_Network_Presentations_2nd_KSE.pdf> accessed 6 April, 2025.

[29] Ritu Bala, Manpreet Kaur, Himani Thakur, Piyush Kashyap, Arun Karnwal and Tabarak Malik, ‘A Sociotechnical Review of Carbon Capture, Utilization, and Storage (CCUS) Technologies for Industrial Decarbonization: Current Challenges, Emerging Solution, and Future Directions’ (2025) International Journal of Chemical Engineering https://doi.org/10.1155/ijce/7195300

accessed 12 September 2025.

[30] International Monetary Fund, Reaching Net Zero Emissions (G20 Background Note, June 2021) https://www.imf.org/external/np/g20/pdf/2021/062221.pdf accessed 12 September 2025.

[31] Natalia Kulichenko and Eleanor Ereira, Carbon Capture and Storage in Developing Countries: A Perspective on Barriers to Deployment (World Bank, Energy and Mining Sector Board Discussion Paper No 25, June 2011) https://ppp.worldbank.org/sites/default/files/2021-09/Carbon%20Capture%20and%20Storage%20in%20Developing%20Countries%20A%20Perspective%20on%20Barriers%20to%20Deployment.pdf accessed 27 July 2025.

[32] Global CCS Institute, Global Status of CCS 2022 (December 2022) https://status22.globalccsinstitute.com/wp-content/uploads/2022/12/Global-Status-of-CCS-2022_Download_1222.pdf accessed 12 September 2025.

[33] INNO‑CCUS, Denmark: State of CCUS Research and Innovation (2nd edn, INNO‑CCUS 2025) https://inno-ccus.dk/wp-content/uploads/2025/05/State-of-CCUS-second-edition-online.pdf accessed 27 July 2025

[34] See, Inflation Reduction Act.

[35] Ryan WJ Edwards and Michael A Celia, ‘Infrastructure to Enable Deployment of Carbon Capture, Utilization, and Storage in the United States’, (2018) 115 (38) Proceedings of the National Academy of Sciences E8815, E8816 <https://doi.org/10.1073/pnas.1806504115> accessed 5 May, 2025.

[36] Ibid.

[37] Janetta McKenzie and Scott MacDougall, ‘Comparing Canadian and American Financial Incentives for CCUS in the Oil Sector’ (Pembina Institute, 2023) <https://climateinstitute.ca/wp-content/uploads/2023/03/comparing-canadian-and-american-incentives-ccus-oil-sector.pdf> accessed 5 May, 2025.

[38] Department of Business, Energy and Industrial Strategy, ‘The Carbon Capture and Storage Infrastructure Fund: An Update on the Design of the CCS Infrastructure Fund’ (UK Government, 2021) <https://assets.publishing.service.gov.uk/media/609427c08fa8f548b0a95f01/ccs-infrastructure-fund-cif-design.pdf> accessed 6 April, 2024.

[39] For discussion of the term “Global South” and its distinction from “developing countries,” see Dados, N. & Connell, R., “The Global South” (2012) 33(1) Contexts 12–13.

[40] Department of Business, Energy and Industrial Strategy, ‘The Carbon Capture and Storage Infrastructure Fund: An Update on the Design of the CCS Infrastructure Fund’ (UK Government, 2021) <https://assets.publishing.service.gov.uk/media/609427c08fa8f548b0a95f01/ccs-infrastructure-fund-cif-design.pdf> accessed 6 April, 2024.

[41] This is based on the conversion rate of N1,409.16./$1. ‘500 Million USD to Naira’, <https://www.fxrateslive.com/USD/NGN/500000000|> accessed 27 March, 2024.

[42] UNFCCC, 2023; World Bank, 2023; IEA and AUC, 2022.

[43] Taiwo Adewale, ‘Financing of CCUS Projects in Nigeria Through the Voluntary Carbon Market. (SSRN, 2023) <https://ssrn.com/abstract=4422136 or http://dx.doi.org/10.2139/ssrn.4422136> accessed 28 March, 2024.

[44] Angela C Jones and Donald J Marples, The Section 45Q Tax Credit for Carbon Sequestration (CRS In Focus IF11455, 25 August 2023) https://www.congress.gov/crs-product/IF11455 accessed 12 September 2025.

[45] Yubing Li, Lei Zeng, Ge Pang, Xueer Wei, Mengheng Wang, Kang Cheng, Jincan Kang, José M. Serra, Qinghong Zhang & Ye Wang, ‘Direct Conversion of Carbon Dioxide into Liquid Fuels and Chemicals by Coupling Green Hydrogen at High Temperature’, (2023) 324 Applied Catalysis B: Environmental 122299 <https://doi.org/10.1016/j.apcatb.2022.122299> accessed 5 April, 2024.

[46] Taiwo Adewale, ‘Financing of CCUS Projects in Nigeria Through the Voluntary Carbon Market. (SSRN, 2023) <https://ssrn.com/abstract=4422136 or http://dx.doi.org/10.2139/ssrn.4422136> accessed 28 March, 2024.

[47] Treaty on the Functioning of the European Union [2012] OJ C326/47, arts 107–109.

[48] Ingvild Ombudstvedt, Lena W Østgaard and Priya Prasad, ‘Playing Nice in the Sandbox: How Coordination and Cooperation with International Neighbors Can Fuel Domestic and Global Deployment of Carbon Capture and Storage’, (2023) 21 (3) Oil, Gas & Energy Law Intelligence 1, 2.

[49] Ibid.

[50] Madeleine J Lewis, ‘The Space Between US: Transboundary Challenges of Geologic Carbon Storage in Interstate and Federal Pore Space’, (2023) 21 (3) Oil, Gas & Energy Law Intelligence 1, 1.

[51] Department of Business, Energy and Industrial Strategy, ‘The Carbon Capture and Storage Infrastructure Fund: An Update on the Design of the CCS Infrastructure Fund’ (UK Government, 2021) <https://assets.publishing.service.gov.uk/media/609427c08fa8f548b0a95f01/ccs-infrastructure-fund-cif-design.pdf> accessed 6 April, 2025.

[52] Martin-Roberts E and others, ‘Carbon Capture and Storage at the End of a Lost Decade’ (2021) 4 One Earth 1569.

[53] Ibid.

[54] Government of Norway and Government of France, Administrative Arrangement Between Norway and France on Cross‑Border CO₂ Transport and Permanent Geological Storage (23 June 2025) https://www.regjeringen.no/en/aktuelt/norway-and-france-establish-arrangement-on-cross-border-CO₂-transport-and-storage/id3111158/ accessed 27 July 2025.

[55] Ibid.

[56] Gassnova, Regulatory Lessons Learned from Longship: The Public Sector’s Involvement in Europe’s First Industrial CCS Chain (CCS Norway, March 2023) https://ccsnorway.com/publication/regulatory-lessons-learned/ accessed 27 July 2025.

[57] See, Monitoring and Reporting Regulation (EU) 2018/2066, Art. 3(52).

[58] Gassnova, Regulatory Lessons Learned from Longship: The Public Sector’s Involvement in Europe’s First Industrial CCS Chain (CCS Norway, March 2023) https://ccsnorway.com/publication/regulatory-lessons-learned/ accessed 27 July 2025.

[59] Gassnova, ‘The Longship CCS Project’ <https://ccsnorway.com/the-project/> accessed 9 April, 2023.

[60]John Litynski1, Traci Rodosta1, Derek Vikara and Rameshwar Srivastava, ‘U.S. DOE’s R&D Program to Develop Infrastructure for Carbon Storage: Overview of the Regional Carbon Sequestration Partnerships and other R&D Field Projects’, (2013) 37 Energy Procedia 6527, 6528.

[61]Ingvild Ombudstvedt and George J Koperna, ‘Comparing Permitting Regimes for CO₂ Storage, Like Comparing Apples and Oranges?’ (2023) 21 (3) Oil, Gas & Energy Law Intelligence 1, 1.

[62] This has made environmental protection organizations criticize the plans for CCS.

[63] Owen L Anderson, ‘Carbon Sequestration: A Fresh Look at an Essential Tool in the War on Climate Change’, (2023) 21 (3) Oil, Gas & Energy Law Intelligence 1, 15.

[64]Juliet Komugisa and Ngozi C Ole, ‘Ugandan Legal Framework on Decommissioning Fund: Is there an Achilles Heel, and can Lessons from the UK Help?’ (2018) 16 (2) Oil, Gas & Energy Law Intelligence 1, 4.

[65] International Energy Agency, Putting CO₂ to Use: Creating Value from Carbon Capture and Storage (IEA 2019) https://www.iea.org/reports/putting-CO₂-to-use accessed 27 Juy 2025]; Ryan WJ Edwards and Michael A Celia, ‘Infrastructure to Enable Deployment of Carbon Capture, Utilization, and Storage in the United States’ (2018) 115(38) PNAS E8815, E8816 https://doi.org/10.1073/pnas.1806504115.

[66]UK Parliament, ‘Climate Change Challenge’ (2019) <https://publications.parliament.uk/pa/cm201719/cmselect/cmscotaf/996/99609.htm#_idTextAnchor049> accessed 8 April, 2024.

[67] Scottish Affairs Committee, The Future of Oil and Gas in Scotland (House of Commons, 2022) HC 776, para 76 https://committees.parliament.uk/publications/9454/documents/161324/default/ accessed 27 July.

[68]Scottish Affairs Committee, ‘The Future of the Oil and Gas Industry’, <https://publications.parliament.uk/pa/cm201719/cmselect/cmscotaf/996/99602.htm> 7 April 2024.

[69] Pablo Rueda and Sofía Polesello, ‘Carbon Capture Storage and Use: Argentina’s Opportunity is Pending New Regulation’, (2023) 21 (3) Oil, Gas & Energy Law Intelligence 1, 4.

[70] Department for Business, Energy & Industrial Strategy, ‘Carbon Capture, Usage and Storage: A Government Response on Re-use of Oil and Gas Assets for Carbon Capture and Storage Projects’ (2020) <https://assets.publishing.service.gov.uk/media/5f36c6df8fa8f51744decfe4/CCUS-government-response-re-use-of-oil-and-gas.pdf> accessed 9 April 2024.

[71] Department for Business, Energy and Industrial Strategy, ‘Carbon Capture, Usage and Storage (CCUS) Projects: Re-Use of Oil and Gas Assets’ (GOV.UK, 17 August 2020) <https://www.gov.uk/government/consultations/carbon-capture-usage-and-storage-ccus-projects-re-use-of-oil-and-gas-assets#:~:text=opportunities%20and%20barriers%20to%20the,the%20handling%20of%20decommissioning%20liabilities> accessed 30 May 2025.

[72]UK Parliament, ‘Climate Change Challenge’, (2019) <https://publications.parliament.uk/pa/cm201719/cmselect/cmscotaf/996/99609.htm#_idTextAnchor049> accessed 9 April 2024.

[73] Rex-CO₂, ‘Re-use assessment of a potential CO₂ storage site in the Netherlands Porthos’ <https://rex-CO₂.eu/documents/REX-CO₂-D4.1-v2021.10.25-Re-use-assessment-Netherlands-PORTHOS-public.pdf> accessed 9 April 2025.

[74]Scottish Affairs Committee, ‘Oral Evidence: The Future of the Oil and Gas Industry’, (House of Commons, 2018) <http://data.parliament.uk/writtenevidence/committeeevidence.svc/evidencedocument/scottish-affairs-committee/the-future-of-the-oil-and-gas-industry/oral/91624.html> accessed 9 April 2024.

[75] Rex-CO₂, ‘Re-use assessment of a potential CO₂ storage site in the Netherlands Porthos’ <https://rex-CO₂.eu/documents/REX-CO₂-D4.1-v2021.10.25-Re-use-assessment-Netherlands-PORTHOS-public.pdf> accessed 9 April 2025.

[76] Department for Business, Energy & Industrial Strategy, ‘Carbon Capture, Usage and Storage: A Government Response on Re-use of Oil and Gas Assets for Carbon Capture and Storage Projects’ (2020) <https://assets.publishing.service.gov.uk/media/5f36c6df8fa8f51744decfe4/CCUS-government-response-re-use-of-oil-and-gas.pdf> accessed 9 April 2025.

[77] UK Government, Energy Act 2023: Explanatory Notes (Division 3: Hydrogen Transport Infrastructure) https://www.legislation.gov.uk/ukpga/2023/52/notes/division/3/index.htm

accessed 12 September 2025.

[78] North Sea Transition Authority, ‘New Tool to Maximise Infrastructure Repurposing’ (21 June 2022) https://www.nstauthority.co.uk/news-publications/new-tool-to-maximise-infrastructure-repurposing/ accessed 12 September 2025.

[79] Nigeria Upstream Petroleum Regulatory Commission (NUPRC), Decommissioning and Abandonment Regulations (2023) [Nigeria Official Gazette].

[80] Nigeria Upstream Petroleum Regulatory Commission (NUPRC), Decommissioning and Abandonment Regulations (2023) [Nigeria Official Gazette]

[81] Offshore Petroleum and Greenhouse Gas Storage Act 2006 (Cth), s 574.

[82] North Sea Transition Authority (NSTA) Screening Tool https://www.nstauthority.co.uk/Regulatory-Information/decommissioning-and-repurposing/repurposing/

[83] Brittany Tarufelli, ‘Overlooked Opportunity: Incentivizing Carbon Capture through Carbon Tax Revenue’

https://www.lsu.edu/ces/publications/2020/overlooked-opportunity-incentivising-carbon-capture-2020-df-web.pdf

[84] https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32009L0031

[85] OSPAR Convention for the Protection of the Marine Environment of the North-East Atlantic (adopted 22 September 1992, entered into force 25 March 1998) 2354 UNTS 67; OSPAR Commission, Decision 2007/2 on the Storage of Carbon Dioxide Streams in Geological Formations (adopted 20 June 2007, entered into force 15 July 2007); OSPAR Commission, Amendments to Annexes II and III to the Convention for the Protection of the Marine Environment of the North-East Atlantic (OSPAR Convention) to Allow Storage of Carbon Dioxide Streams in Geological Formations (adopted 20 June 2007, entered into force 23 July 2011). Protocol to the Convention on the Prevention of Marine Pollution by Dumping of Wastes and Other Matter (adopted 7 November 1996, entered into force 24 March 2006) 2241 UNTS 416 (London Protocol), as amended 2006.

[86] OSPAR Convention for the Protection of the Marine Environment of the North-East Atlantic (adopted 22 September 1992, entered into force 25 March 1998) 2354 UNTS 67; OSPAR Commission, Decision 2007/2 on the Storage of Carbon Dioxide Streams in Geological Formations (adopted 20 June 2007, entered into force 15 July 2007); OSPAR Commission, Amendments to Annexes II and III to the Convention for the Protection of the Marine Environment of the North-East Atlantic (OSPAR Convention) to Allow Storage of Carbon Dioxide Streams in Geological Formations (adopted 20 June 2007, entered into force 23 July 2011). Protocol to the Convention on the Prevention of Marine Pollution by Dumping of Wastes and Other Matter (adopted 7 November 1996, entered into force 24 March 2006) 2241 UNTS 416 (London Protocol), as amended 2006.

[87] Preamble, paras. 12-14.

[88] Council Directive 85/337/EEC, European Parliament and Council Directives 2000/60/EC, 2001/80/EC, 2004/35/EC, 2006/12/EC, 2008/1/EC and Regulation (EC) No 1013/2006.

[89] UK Energy Act 2023, Part 2 (Carbon Dioxide Transport and Storage Licensing).

[90] Regulations relating to transportation and storage of CO₂ on the continental shelf (CO₂ Storage Regulations) (FOR-2014-12-05-1517) (Norway).

[91] UK Energy Act 2023, Part 2 (Carbon Dioxide Transport and Storage Licensing).

[92] Department of Energy Security and Net Zero, ‘UK Carbon Capture, Usage and Storage (CCUS)’ (GOV.UK) <https://www.gov.uk/government/collections/uk-carbon-capture-usage-and-storage-ccus> accessed 30 May 2025.

[93] Mohammad Nooraiepour, Pawel Gladysz and Eirik Melaaen, ‘Norwegian–Polish Carbon Capture and Storage Network: Bilateral Collaboration for European Climate Action’ (2025) 126 Energy Research & Social Science 104106 https://doi.org/10.1016/j.erss.2025.104106 accessed 12 September 2025.

[94] Nooraiepour M, Gladysz P and Melaaen E, ‘Norwegian–Polish Carbon Capture and Storage Network: Bilateral Collaboration for European Climate Action’ (2025) 126 Energy Research & Social Science 104106.

[95] Ibe, A. P., and A. S. Nwosi-Anele. "Framework for Carbon-Capture and Storage (CCS) in Nigeria." Paper presented at the SPE Nigeria Annual International Conference and Exhibition, Lagos, Nigeria, August 2024 https://doi.org/10.2118/221616-MS

[96] Damilola Olawuyi, ‘From Energy Consumers to Energy Citizens: Legal Dimensions of Energy Citizenship’ in K Hunter et al (eds) Sustainable Energy Democracy and the Law (Netherlands: Brill, 2021) 101-123.

[97] Ibid.

[98] Brittany Tarufelli, ‘Overlooked Opportunity: Incentivizing Carbon Capture through Carbon Tax Revenue’

https://www.lsu.edu/ces/publications/2020/overlooked-opportunity-incentivising-carbon-capture-2020-df-web.pdf

[99] ‘The Innovation Fund was established by Article 10a(8) of Directive 2003/87/EC to support across all Member States innovation in low-carbon technologies and processes.’ https://climate.ec.europa.eu/eu-action/eu-funding-climate-action/innovation-fund_en

[100] Vikram Vishal, Debanjan Chandra, Udayan Singh, Yashvardhan Verma, ‘Understanding initial opportunities and key challenges for CCUS deployment in India at scale’ (2021) 175 Resources, Conservation and Recycling, 105829. See also IEA, ‘CCUS Technology Innovation’ https://www.iea.org/reports/ccus-in-clean-energy-transitions/ccus-technology-innovation

[101] Ogbo, Ojiako & Onuoha, David & Odoh, Chijioke. (2024). Carbon Capture and Storage (CCS) in Nigeria: A Review of Challenges and Opportunities. British Journal of Multidisciplinary and Advanced Studies. 5. 1-18. 10.37745/bjmas.2022.04148.

[102] Damilola Olawuyi, ‘From Technology Transfer to Technology Absorption: Addressing Climate Technology Gaps in Africa’ (2018) 36:1 Journal of Energy & Natural Resources Law 61-84.

[103] Ibid.

[104] See Onuh, Peter & Ejiga, James & Abah, Emmanuel & Onuh, Joy & Christian, Idogho & Omale, Joseph. (2024). Challenges and Opportunities in Nigeria's Renewable Energy Policy and Legislation. Journal of Advanced Research. 23. 2354-2372. 10.30574/wjarr.2024.23.2.2391.

[105] Butz, Heiko & Mrożewski, Matthias. (2021). The Selection Process and Criteria of Impact Accelerators. An Exploratory Study. Sustainability. 13. 6617. 10.3390/su13126617.

[106] Olawuyi (n.83); also Ibe, A. P., and A. S. Nwosi-Anele (n.82).

Legal Implications of Re-Use of Decommissioned Petroleum Infrastructure for Carbon Capture, Utilisation and Storage Projects*

Abstract