2026全球碳捕集与封存 (CCS) 风险报告：二氧化碳封存许可管理、转让与责任研究

May 2026 Disclaimer This Report was prepared by Ashurst (theAuthor) on request by the Oil and Gas Climate Initiative (OGCI). Thecopyright in this Report is owned by OGCI (on behalf of the OGCI and the OGCI members). The document isinformational; the opinions and recommendations expressed do not necessarily reflect the positions of eachOGCI member company. The views expressed in this Report, including its conclusions and recommendations,do not necessarily represent the views of OGCI or its member companies. Whilst every effort has been madeto ensure the accuracy of this Report, OGCI, its member companies and the Author do not warrant its accuracyand, regardless of its or their negligence, do not assume liability for any use made of this Report or for any loss ordamage arising from any interpretation or use of the information contained in this Report, or reliance on any viewsexpressed therein, which liability is hereby excluded. Ashurst is a global law firm. The Ashurst Group comprises Ashurst LLP, Ashurst Australia and their respectiveaffiliates (including independent local partnerships, companies or other entities) which are authorised to use thename "Ashurst" or describe themselves as being affiliated with Ashurst. Some members of the Ashurst Group arelimited liability entities. Information about which Ashurst Group entity operates in any country can be found on ourwebsite at www.ashurst.com. This material is current as at November 2025 but does not take into account any developments to the law afterthat date. It is not intended to be a comprehensive review of all developments in the law and in practice, or tocover all aspects of those referred to, and does not constitute legal advice. The information provided is general innature, and does not take into account and is not intended to apply to any specific issues or circumstances. Readers should take independent legal advice. No part of this publication may be reproduced by any processwithout prior written permission from Ashurst. While we use reasonable skill and care in the preparation of thismaterial, we accept no liability for use of and reliance upon it by any person. © Ashurst 2026 Table of contents Executive summary7 Phase 1A works – international law analysis:international regulations on carbon capture and storage10 1972 – London Convention151974 – SOLAS171978 – MARPOL Protocol to 1973 Convention171982 – UNCLOS181989 – Basel Convention (as amended)221991 – Espoo Convention241992 – Helsinki Convention241992 – CBD251992 – OSPAR Convention261996 – London Protocol, as amended in 2006272010 – HNS Convention and Protocol (not yet in force)29 Climate treaties31 1992 – UNFCCC (and IPCC reporting)331997 – Kyoto Protocol362015 – Paris Agreement (and Article 6 crediting)37 Phase 1 works – identify and summarise existing framework41 Observation 1 – a majority of the regimes we selected to include in our analysis allocate liabilitiesbetween previous owners / operators, current / future storage owners, and government42Observation 2 – none of the Selected Jurisdictions allow for “license conversion”42Observation 3 – a majority of regimes include post-closure regimes42 Summary43Transfer liabilities46Post-closure liabilities48Barriers to transfer49 United States of America – Wyoming51 Summary51Transfer liabilities52Post-closure liabilities53Barriers to transfer54 Summary56Transfer liabilities58Post-closure liabilities59Barriers to transfer60 United States of America – Texas62 Summary62Transfer liabilities63Post-closure liabilities64Barriers to transfer65 United States of America – California66 Summary66Transfer liabilities67Post-closure liabilities68Barriers to transfer68 Summary69Transfer liabilities70Post-closure liabilities71Barriers to transfer71 United States of America – New Mexico72 Summary72Transfer liabilities73Post-closure liabilities73Barriers to transfer76 Brazil77 Summary77Transfer liabilities78Post-closure liabilities80Barriers to transfer81 United Kingdom82 Summary82Transfer liabilities83Post-closure liabilities86Barriers to transfer88 Canada – Alberta89 Summary89Transfer liabilities90Post-closure liabilities93Barriers to transfer95 Summary96Transfer liabilities96Post-closure liabilities98Barriers to transfer101 Australia – Commonwealth104 Summary104Transfer liabilities105Post-closure liabilities109Barriers to transfer110Additional observations of relevance112 Summary114Transfer liabilities115Post-closure liabilities116Barriers to transfer117 Australia – Victoria (onshore)118 Summary118Transfer liabilities119Post-closure liabilities121Barriers to transfer123 Australia – Queensland125 Summary125Transfer liabilities126Post-closure liabilities128Barriers to transfer129 Australia – South Australia131 Summary131Transfer liabilities132Post-closure liabilities134Barriers to transfer135 Summary137Transfer liabilities138Post-closure liabilities140Barriers to transfer142 Italy143 Summary143Current GGS titleholder obli