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Scope 3 emissions: the growing regulatory and legal risks facing the UK North Sea

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UK upstream companies face being held to a higher standard on Scope 3 emissions than any other country, as the government strives to meet its legal obligations on climate change. An ongoing consultation is expected to require companies to measure Scope 3 emissions and propose mitigation measures to obtain government approval for new projects. Since July 2024, no pathway exists for companies to obtain such approvals in the UK North Sea. For some operators, this inability to commercialise resources, is the most fundamental issue facing them today. The growing risk of legal challenges combined with a heavier regulatory burden in a mature basin with declining cash flows could force some operators to withdraw or divert investment in less stringent countries which have more Scope 1&2 emissions-intensive production than the UK.

Table of contents

    • The UK's Scope 3 emissions consultation
    • What are Scope 3 emissions?
    • The proposals
    • Impact of delays on Jackdaw and Rosebank
    • Legal risks intensifying
    • The Wood Mackenzie emissions advantage – Scope 3 data in Lens
    • Footnotes

Tables and charts

This report includes the following images and tables:

  • UK oil & gas supply/demand ranges under different scenarios
  • Scope 1&2 emissions intensity of North Sea piped gas supply versus LNG imports
  • Upstream project sanctions since Jackdaw July 2022
  • UKCS capital expenditure by development status
  • Economic impact of delays on 1) Jackdaw and 2) Rosebank
  • Energy & climate change civil law judicial reviews in England & Wales

What's included

This report contains:

  • Document

    Scope 3 emissions: the growing regulatory and legal risks facing the UK North Sea

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