EU mandates operational CO₂ injection capacity by 2030 – creating a new market with Romania at the centre

Under the Net Zero Industry Act (Regulation (EU) 2024/1735, referenced as “NZIA”), the EU has set a binding target of 50 million tonnes of operational CO₂ injection capacity by 2030. Recent delegated acts identify the EU-based oil and gas producers subject to NZIA obligations and specify their pro rata contributions. Romanian producers account for over 20% of these obligations, positioning Romania as a core player in Europe’s emerging CO₂ storage system.

Romania’s significant share of the target, combined with its favourable geology – particularly depleted fields suitable for conversion into permanent CO₂ storage sites – creates major opportunities for developing storage capacity and associated transport and midstream infrastructure.

1. Mandatory CO₂ injection capacity under NZIA

Although carbon capture technologies are increasingly viable in the EU, they cannot be deployed at scale without reliable access to permitted CO₂ geological storage sites. Through the NZIA, the EU aims to address a market coordination problem: industries ready to capture CO₂ risk having nowhere to store it, while investors in storage face high upfront costs before being able to apply for permits. By improving transparency on geological data, requiring EU member states to report progress on storage development and creating a predictable investment environment, the NZIA seeks to align capture, transport and storage investments into functioning value chains.

The regulation positions CO₂ injection and permanent geological storage as essential to achieving climate neutrality. To this end, the NZIA requires EU‑licensed oil and gas producers to develop 50 million tonnes of annual operational CO₂ injection capacity by 2030. To reach this objective, oil and gas licensees must contribute proportionately to developing storage capacity, calculated pro rata to their 2020–2023 crude oil and natural gas production.

Through the 2025 implementing measures (Commission Delegated Regulation (EU) 2025/1477 referenced as the “Delegated Regulation” and Commission Decision (EU) 2025/1479, referenced as the “Commission’s 2025 Decision”), the EU enacted the binding list of obligated entities and their exact CO₂ injection capacity obligations. The five largest contributors bound by the Commission’s 2025 Decision are:

• Netherlands‑based producers: ~ 13,960 kt/year (approx. 26.64%)
• Romania‑based producers: ~ 10,250 kt/year (approx. 20.50%)
• Italy‑based producers: ~ 6,950 kt/year (approx. 13.90%)
• Germany‑based producers: ~ 5,370 kt/year (approx. 10.74%)
• Poland‑based producers: ~ 4,260 kt/year (approx. 8.52%)

To meet their targeted volumes, producers: may invest in or develop CO₂ storage projects alone or through joint ventures, enter into agreements with other obligated producers or contract with third‑party storage developers.

As per the Delegated Regulation, if an obligated oil and gas producer ceases to legally exist by 31 December 2030 or if the relevant authorisation is transferred, the contribution obligation is assumed by the subsequent authorisation holder. However, the Delegated Regulation does not address the scenario in which the obligated producer ceases to exist through winding up or insolvency procedure before 31 December 2030. In such a case, where the CO₂ injection obligations are not commercially assigned within or as a consequence of those proceedings, it is arguable that the member state would ultimately need to ensure continuity – since the EU wide target of 50 Mt/year must still be met and the obligation cannot remain without a bearer. Given this regulatory gap, further national measures would be required to ensure uninterrupted assumption of the obligation and to prevent the CO₂ injection contribution requirement from becoming ownerless.

Key timelines under the NZIA include the reporting of producers and volumes by Member States by 30 September 2024, the Commission’s specification of contributions in 2025, submission of delivery plans by obligated entities by 30 June 2025, annual progress reports starting 30 June 2026 and national penalties set by 30 June 2026.

The 2030 injection‑capacity target is only the starting point for the much larger volumes expected by 2050. For this, the NZIA requires member states to actively facilitate capture and storage (“CCS”) deployment, remove barriers, support CO₂ transport infrastructure and create conditions for a competitive and accessible market for CO₂ injection and transport services.

2. Romania’s >20% share: volumes and market implications

The Commission’s 2025 Decision lists individual obligations. For Romania‑based producers, the Commission’s 2025 Decision sets approximately: OMV Petrom SA 5,880 ktpa, S.N.G.N Romgaz SA 4,120 ktpa and Black Sea Oil & Gas SA 250 ktpa – totalling just over 10 Mt/year by 2030, slightly above 20% of the 50 Mt/year Union target.

Romanian policy documents also reference an obligation of approximately 9 Mt/year by 2030, the EU’s second‑largest national burden, illustrating the scale and urgency of investment needed in storage capacity and midstream infrastructure.

Given these volumes, Romania will require multiple permitted storage sites with market‑ready injection capacity by 2030, supported by CO₂ gathering, compression and transport systems (pipeline and potentially maritime, road or rail) to connect emitters to storage.

Storage options include saline aquifers and depleted hydrocarbon fields, both eligible under the NZIA and CCS Directive 2009/31/EC (the “CCS Directive”) frameworks. The National Regulatory Authority for the Mining, Petroleum and Geological Storage of Carbon Dioxide (“ANRMPSG”) is responsible for designating the areas within Romania where storage sites may be selected and for publishing these areas on its official website. ANRMPSG also evaluates the available storage capacity in the identified zones, including by authorising exploration activities in accordance with the applicable regulatory framework. In 2025, a Primary Assessment of Regions in Romania for Geological CO₂ Storage was uploaded on the ANRMPSG website, identifying eight morpho-structural regions of Romania where CO₂ storage sites may be selected based on geological suitability.

The Delegated Regulation recognises non‑obligated (i.e. below threshold) producers operating storage sites as potential third‑party developers, enabling capacity‑as‑a‑service models.

For industrial emitters, the annual reports required from obligated producers will disclose essential information such as sites, capacities, timelines, CO₂ quality, transport modes, final investment decision (“FID”) and operational dates – information needed to negotiate long‑term storage contracts.

3. Romania’s legal steps for NZIA implementation

Romania has updated its national CCS framework to align with the NZIA and accelerate storage build‑out as follows:

• Through Emergency Governmental Ordinance No.139/2024 (“EGO 139/2024”), Romania amended Emergency Governmental Ordinance 64/2011 (CCS Directive transposing act) to allow storage authorisation to be issued directly to existing petroleum titleholders when the site is already characterised and the titleholder demonstrates technical and financial capacity.
• The act also terminates hydrocarbon agreements for areas converted to storage sites while preserving obligations for the remaining perimeter.
• EGO 139/2024 mandates transparent, non‑discriminatory access rules: the National Energy Regulatory Authority (“ANRE”) approves access to CO₂ transport infrastructure, ANRMPSG sets storage‑site access rules and ANRE oversees tariff dispute resolution.
• ANRMPSG must establish procedures for access to the National Geological Fund to support site selection and capacity assessment.
• CO₂ transport licensing is integrated under ANRE, formalising midstream regulation.

In addition, as recently as June 2025, ANRMPSG issued new instructions for verifying, among other matters, the financial and technical capacity of CO₂ storage entities.

These legal measures clarify permitting pathways, open‑access principles, institutional roles and alignment with NZIA obligations.

4. What companies should do now

• Obligated oil and gas producers: Finalise bankable project portfolios and/or third‑party capacity contracts to deliver your allocated Mt/year by 2030 and to align FIDs and permitting with NZIA reporting duties and Romania’s new fast‑track conversion route for eligible hydrocarbon perimeters.
• Third‑party storage developers: Advance site screening in saline aquifers and depleted fields using National Geological Fund pathways design open‑access multi‑client storage services and position for offtake from obligated producers and EU Emissions Trading System emitters under the NZIA framework.
• Industrial emitters: Map capture timelines to announced storage injection dates and transport corridors and negotiate long‑term storage capacity and CO₂ quality specifications early, leveraging transparency and annual reporting to de‑risk FID.
• All market participants: Track ANRMPSG/ANRE rulemaking on access, tariffs and licensing and ensure that financial and technical capability documentation meets ANRMPSG standards to avoid permitting delays.

5. Conclusion

Romania now holds a significant competitive position: with one of the largest EU‑mandated storage obligations and a regulatory system adapting to enable rapid project deployment, it is positioned to become a key CO₂‑storage and transport hub for Central and Eastern Europe. For investors, storage developers, midstream operators and industrial emitters seeking long‑term scalable solutions, Romania could offer not only capacity but strategic positioning within the EU’s emerging CO₂ value chain.

Stakeholders exploring opportunities, assessing regulatory implications, evaluating partnerships or seeking preliminary discussions are welcome to contact us for further information.