Effective penalties are key to delivering Article 23 of the EU’s Net-Zero Industry Act (NZIA). Member States must establish enforcement regimes by 30 June 2026, ensuring the cost of non-compliance exceeds the cost of compliance, while keeping penalties proportionate and avoiding placing compliant entities at an economic disadvantage. This briefing unpacks the key design principles and approaches Member States should consider to enable timely delivery of Europe’s 50 Mt/year CO₂ injection capacity target by 2030.

Read Article 23 Watch’s briefing to learn what effective penalty design looks like — and why the decisions Member States make now are critical to turning Article 23 from obligation into action.

Article 23 – Designing penalties to ensure compliance with the EU CO₂ storage obligation

This briefing outlines the key design principles for penalty regimes, what enforcement models work best, and how Member States can ensure the cost of non-compliance exceeds the cost of compliance under Article 23.

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