NZIA feasibility report: Is the NZIA achievable from a full value-chain perspective?

When the EU introduced the Net Zero Industry Act in 2024, Article 23 set a clear mandate: deliver 50 million tonnes per annum of CO₂ injection capacity by 2030. Our latest analysis suggests something important—framing the challenge purely around storage capacity misses the fundamental issue confronting CCS development across Europe. The real bottleneck lies elsewhere across the value chain. 

We were commissioned by ExxonMobil, OMV Petrom, Shell, and TotalEnergies to assess whether this storage target remains feasible from a full value-chain perspective. Our investigation expanded well beyond injection capacity to examine capture, transport, and storage as an integrated system. What we discovered challenges conventional thinking about where the CCS problem actually sits. 

The findings matter for policy-makers, project developers, and anyone tracking Europe's progress on carbon abatement. The gap between regulatory ambition and operational reality is widening rapidly. Yet it is not because storage operators lack the will or capability to deliver capacity. 

Here's what our analysis uncovered:

Our projection shows EU injection capacity will fall short by at least 16.5 million tonnes per annum—35% below the mandated target. But here is the critical insight: this shortfall is not primarily a storage problem. It reflects fragmentation across capture, transport, and storage operating on misaligned timelines and regulatory frameworks.

We identified four structural barriers constraining progress:

• Fragmented value chains. Capture, transport, and storage projects advance independently rather than in parallel. Storage operators cannot reach Final Investment Decision without firm capture volume commitments. Capture facilities cannot secure financing without guaranteed storage access. Transport infrastructure remains absent from the policy framework entirely. 

• Persistent project delays. European carbon storage projects require over eight years on average from exploration to operations. Nearly all EU storage projects have experienced delays averaging one-and-a-half years beyond original timelines. Recent announcements suggest this figure is increasing rather than stabilising. 

• Challenging capture economics. Many capture facilities remain uneconomic without substantial public subsidy. Several high-profile projects have paused recently, citing insufficient financing and high risk exposure. Capture cannot close its financing gap through carbon pricing alone. 

• Insufficient supply for EU stores. Geography creates a critical constraint. Large swathes of industrial emissions across Central and Eastern Europe remain disconnected from planned transport infrastructure. EU capture volumes also face competition from established Norwegian storage options. 

The NZIA attempts to resolve the classic "chicken and egg" problem by mandating storage capacity. Yet it does so without ensuring parallel progress on capture or transport. The result is a value chain governed by incompatible incentives where no single element can progress independently. 

This is where our full analysis becomes essential. We have mapped the specific barriers, quantified the gaps, and assessed what genuine value-chain integration might require. The implications extend across policy design, capital allocation, and project strategy across the entire continent. 

To access our complete findings and detailed recommendations, fill out the form at the top of the page to access your complimentary copy of the full report.