Although the concept has been around for decades, the unique events of the past 18 months have rapidly propelled CCS from the fringe onto the main stage. All the industry’s largest companies now have at least one slide in their strategy decks showing how they will meet a big wedge of their decarbonisation target via subsurface sequestration. However, we believe the regulatory, commercial, and technical hurdles still to be overcome are significantly underestimated. Discussions with both existing and aspirational CCS operators convey a clear message: hitting targets will be very challenging. We analyse the scale of the challenges ahead for upstream CCS through the prism of three key metrics: regulatory, commercial and subsurface.