CDR Policy Progress Across Europe 2025-2026 Update

It has been a year since Carbon Gap released its Policy Tracker 2.0 with analyses of national policies across Europe’s largest economies and most advanced actors. Users have since been able to compare regional progress in the implementation of effective CDR policy. This report highlights the changes and developments that have occurred since then, and outlines what might await us in the coming year.

Carbon Gap’s analysis of the countries’ policy progress toward establishing robust carbon dioxide removal (CDR) policies is formed on the basis of a Traffic-Light Framework. Its primary purpose is to provide a high-level evaluation of national policy environments. Rather than offering a rigid checklist of required policies, the framework highlights the essential elements that should be considered in a near- to medium-term national CDR strategy.

The framework is structured around three enabling conditions and four pillars, which together form eight main indicators and twenty-four sub-indicators. These cover a range of critical areas, from setting clear targets and developing national strategies to clarifying regulatory rules, investing in research and innovation, and ensuring just governance and deployment. Each indicator is assessed on a four-tiered scale—on track, clear signs of progress, early signs of progress, or no signs of progress—which reflects the maturity, ambition, and detail of policies in place. Priority indicators are weighted more heavily in the scoring system, rewarding countries that implement binding instruments or tailored mechanisms over more generic or indicative approaches. The assessment relies on desk-based research and collaboration with local experts to ensure accuracy and comparability, with progress consolidated into a final score for each indicator.

This policy progress report accompanies an update to the current scoring matrix found on Carbon Gap’s Policy Tracker website. The indicators of the final matrix aggregate the variations of different sub-indicators. Furthermore, each scoring tier is set at a specific threshold. As such, incremental policy changes and progress are not always visible on a year-to-year basis. This report therefore also serves to highlight those piecemeal policy updates.

In 2026, European countries are much closer in terms of implementing effective CDR policy than they were a year ago. Switzerland has made significant improvements according to our framework, now leading Europe together with Denmark and Germany. Indeed, Germany took important steps in its CDR policy mix and is now firmly in a leading position in Europe. Behind these three leaders, Finland and the United Kingdom (UK) also progressed and together with the Netherlands, France, and Sweden constitute the next most advanced group of European countries on CDR. Italy also made significant progress relative to its starting point in 2025, and Poland is working on important improvements for the upcoming year. Although the leading  countries in CDR policy haven’t progressed much beyond the 2024-2025 starting point, Europe as a whole is improving steadily. The spread of progress on CDR policy is therefore much narrower than it was last year.

Figure 1: Key policy milestones achieved in 2025

In our scoring matrix, Norway has regressed because the state repealed its political commitment to net-zero. With no sign ahead of a legally binding net zero target, Norway nevertheless remains a crucial node in Europe’s CDR ecosystem due to its advanced CO₂ storage capacities and infrastructure. Sweden has similarly slightly regressed because it has repealed some of its carbon taxes, despite still having one of the stronger carbon tax regimes in Europe and remaining a leader in CDR policy and industry.

In the summative table below (Figure 2) and in all the maps that follow, the colour of cells represents CDR policy development for each of the 11 countries we have assessed as of April 2026. The filled arrows represent a change in policy development tier compared to 2025. The hollow arrows represent changes in CDR policy which affected the underlying scores without having an impact on the overall tier of policy development. Asterisks symbolise retroactive changes to our 2025 assessment made in light of updated information. Upward arrows represent improvements and downward arrows setbacks.

Figure 2: Summative assessment of regional CDR policy developments

CDR Strategy

National CDR strategies set the direction of travel for CDR, clarifying ambition, outlining different phases of policy support, and serving as a launching ground for concerted action. Having a strategy is essential to provide certainty for investors and market actors.

So far, Switzerland and the Netherlands are the only two countries in Europe with dedicated strategies for CDR. Both are organised around scale-up phases, first focusing on innovation and early pilots before moving toward industrial deployment. Switzerland’s strategy is more operational and focuses on leveraging Direct Air Capture while the Netherlands’ roadmap is broader, focusing on policy architecture, European market creation, and the country’s role as an export hub.

Germany has made the most progress on this front, but its final negative emissions strategy has still not been published. The draft foresees potentially binding CDR milestones, monitoring reporting and verification (MRV) aligned with the European Union’s (EU) Carbon Removal and Carbon Farming (CRCF) Regulation, and government support along the lines of Contracts-for-Difference.

The UK has not published a standalone CDR strategy, but the latest Carbon Budget and Growth Delivery Plan outlines how the recently published GGR Business Model, GGR Standard, and the integration of CDR (or potential thereof) into CCUS industrial clusters and the UK ETS will all contribute to the UK achieving 21.8MtCO₂e removals by 2035.

In March 2025, Poland’s Climate and Energy ministry and key stakeholders signed a letter of intent for CCUS which provides a roadmap for CCUS in place of an official strategy. Even though this document isn’t intended for CDR, the legal framework, infrastructure, development model, and support mechanisms designed for CCUS would likely be applicable to CDR as well. Nevertheless, the Polish government is intent on developing a dedicated CDR strategy in the upcoming year.

Setting targets

In 2025, the EU only had a target to reduce 55% of its emissions by 2030. Most EU Member States had established their own net-zero or climate neutrality targets in law or policy, though the ambition, legal bindingness, and treatment of CDR varied considerably.

In the past year, most notably, the European Union has adopted a 2040 target. On aggregate, EU Member States must now reduce their emissions by 90% by 2040 relative to 1990 levels, but 5% of those emissions reductions can be met through the use of international carbon credits.

In December 2025, the Danish government set an 82% emissions reductions target for 2035 compared to 1990 levels through a unilateral executive move by the government. This move represents an additional 12% emissions reductions compared to the 2030 target set in the country’s 2020 Climate Act. The legislative confirmation of this target is expected in 2026.

The Dutch government clarified its 2030 negative emissions target in its 2025 Subplan on access to external CO₂. The previous target of 1.5MtCO₂ is to be achieved through the SDE++ scheme, while the broader government target for removals ranges from 0 to 3.5MtCO₂e by 2030.

The latest draft of the French National Low Carbon Strategy projects that France will need to maintain at least 24 Mt CO₂e of carbon sequestration from natural sinks and 21 Mt CO₂e from BECCS and DACCS by 2050. Similarly, the British Carbon Budget and Growth Delivery Plan projects that the UK will need 23MtCO₂ of engineered removals by 2035. However, these targets are indicative and non-binding.

As mentioned at the start of this report, Norway repealed its commitment to climate neutrality by 2030, and only emissions reductions targets remain for the country.

Clarifying rules

Having a clear set of rules ensures that CDR contributes to robust climate outcomes whilst minimising other harms. Certification mechanisms, biomass sustainability standards, MRV rules, and rules for climate claims all help to govern the impact of CDR and limit false or misleading claims. Countries may also outline whether and how they account for removals in their national carbon accounting, including whether they plan to use Article 6 of the Paris Agreement to transfer removals from or to other territories. Overall, over the past year, the number of certification mechanisms has increased in Europe, as has their robustness. Yet only the EU’s CRCF and the British Standards cover permanent CDR. Other rules for claims across Europe have been subject to mixed developments.

The European Union as a whole regressed on rules for claims in the past year due to the collapse of negotiations on the proposed Green Claims Directive and the broad Omnibus Regulation simplifications and scope reduction of the Corporate Reporting Sustainability Directive (CSRD). Nevertheless, certification standards have been developed for different CDR methodologies under the EU’s Carbon Removal and Carbon Farming (CRCF) Regulation. The methodologies for permanent CDR have been tentatively adopted, while carbon farming methodologies are expected before the end of 2026.

On the other hand, Switzerland has so far maintained its regulation matching the original CSRD through the implementation of its Unfair Competition Act, the revision of the Climate Innovation Act, and the revision of the Climate Protection Ordinance. Switzerland and Norway also took a significant first step in the past year when they traded the first international CDR credits through Article 6.2 of the Paris Agreement. The alpine country is also planning to trade CDR credits with Kenya.

For its part, the UK’s Competition & Markets Authority published supplementary guidance and principles on green claims in early 2026. To add to its nature-based Woodland Code and Peatland Code, the British Standards Institution published drafts of certification standards for BECCS and DACCS with finalisation expected by 2027. Furthermore, initial drafts and piloting of the national Saltmarsh Carbon Code were due by the end of 2025 but are yet to be published. On safeguards, the UK has made some progress with the expansion of peatland protections and the completion of the consultation on the biomass sustainability framework.

France’s Label Bas Carbone remains one of the most advanced national certification schemes including nature-based removals in Europe. It was amended in the past year to enable carbon trading and clarified rules on third-parties and intermediaries. Following a royal decree in June 2025, the previously voluntary Spanish certification scheme for carbon credits transitioned into a mandatory reporting instrument aligned with the original EU Corporate Sustainability Reporting Directive (CSRD). Italy launched its own registry for voluntary nature-based carbon credits in October 2025 initially only for forestry, with standards for agricultural carbon farming still in development.

In Sweden, there has been some movement on clarifying the role of carbon removals in its National Energy and Climate Plan. The Environmental Objectives Commission report from 2025 proposed revised accounting rules, but these suggestions have yet to be taken to the Swedish parliament. The 2025 Climate Policy Council report also states that Sweden should develop a clear process to better quantify biogenic emissions and agricultural climate contributions.

Overall, European countries have improved and clarified rules for claiming  and accounting CDR. However, as part of clarifying use-cases for CDR, the UK government is also considering integrating woodland credits in its ETS. If implemented, this would infringe upon other important safeguards such as the Like-for-Like Principle, but no official decision has yet been made on this integration.

Developing infrastructure

Policies on CDR physical infrastructure in Europe have seen quite a lot of developments in the past year spanning the ratification of the London Protocol Article 6 amendment, important amendments to carbon transport and storage laws as well as permitting and licensing accommodations for CDR in the UK, Germany, Finland, and Sweden.

One of the essential foundations for the development of permanent CDR in Europe is the widespread ratification of the London Protocol Article 6 amendment on transboundary transport and storage of CO₂. France ratified the amendment in June 2024, while Germany did so in February 2026.

From this basis seven bilateral agreements between countries in Europe on the transport and storage of CO₂ were signed in the past year. Denmark has signed agreements with Belgium, the Netherlands, Finland, and Switzerland. Switzerland has also signed agreements with the Netherlands and Iceland, while Norway and France have signed a Memorandum of Understanding, and Sweden is considering potential agreements with the Netherlands and the UK.

As mentioned earlier, Germany and the UK have made the most progress with regards to the legal framework for CDR infrastructure. In Germany, the amended Carbon Dioxide Storage Act is now in effect. The law allows offshore underground geological storage outside of marine protected areas and maintains the prohibition of onshore geological storage by default (except in the case of research while delegating the choice to allow it in future to Länder). The law also establishes a regulatory framework for CO₂ pipelines into energy law. The amended Carbon Dioxide Storage Act empowers state authorities to expropriate private land, with compensation, for the construction of CO₂ pipelines, but none of the sixteen Länder have so far expressed any intention to use this ability. The amendment has also streamlined licensing procedures for CO₂ transport explicitly, especially where these are adjacent to planned hydrogen pipelines. Lastly, in April 2026, the German federal government relaunched the previously stalled consultation for the country’s carbon management strategy.

In the UK, the CCS Network Code released mid-2025 and updated in early December 2025 sets out liability arrangements for CO₂ infrastructure, and as part of the UK ETS integration of Greenhouse Gas Removals, liability regimes will also be further developed. The Code addresses risk management, including provisions for handling CO₂ leaks, storage site integrity, and transport infrastructure damage, while setting out liability arrangements for operators. It requires transparency in operations, with mandatory reporting on CO₂ emissions, transport, and storage data to keep regulators and stakeholders informed. Additionally, it ensures third-party access to CCS infrastructure under fair terms and outlines pricing and tariff structures to encourage competition and investment.

A government consultation on CO₂ infrastructure highlights likely developments in terms of access to CCUS infrastructure while CCUS cluster sequencing programmes have progressed to support at least one BECCS project for launch by 2028. At the end of 2025, the government published technical guidance on marine geological storage and on the processes for securing Carbon Storage Licenses. This guidance includes clear licensing timelines and administrative steps.

Over the past year, Finland has made substantial progress on permitting and licensing for CDR and CCUS. A new Licensing and Supervision Agency (Lupa- ja valvontavirasto) began operations on 1 January 2026 after the Act on the Processing of Certain Environmental Matters entered into force. It aims to process multiple permit applications (e.g., environmental impact assessments, Natura assessments) together to speed up investment projects, including those for industrial carbon management.

Similarly, Sweden’s 2026 Budget boosts environmental permitting efficiency with a SEK 161 million increase for key agencies (EPA, Radiation Safety, Courts, etc.) to speed up permitting processes, especially for new nuclear and renewables. The budget also includes plans for a new environmental assessment authority from 2027 to streamline approvals, creating a faster, clearer system for sustainable development. Although not explicitly related to permitting for CDR or CCS, industrial carbon management is likely to also benefit from these upcoming changes.

In Switzerland and Sweden, an adopted motion and a consultation respectively on carbon management infrastructure indicate that more progress is expected in the coming year.

Carbon Gap’s Carbon Removal Readiness Assessment (CRRA) reports have significantly contributed to the quantification of potential carbon storage in Germany, Finland, Italy and Poland. In some countries like Switzerland, research on storage potential continues but is often limited to specific areas or reservoirs. In early 2025, the EVASTOCO2 study extensively quantified the total geological storage potential in France, complementing Carbon Gap’s 2024 CRRA and quantification carried out in the National Low Carbon Strategies.

Although Norway has not made progress in terms of CDR infrastructure policy, the inauguration of the Northern Lights project and the start of phase 2 represent a significant milestone for carbon management in Europe, and CDR too since the launch of the project’s second phase was made possible by securing an agreement to store 900,000 tCO₂ from Stockholm Exergi.

Supporting RD&I

Robust government support for research, development and innovation (RD&I) naturally requires targeted public funding plans, but it also requires efforts to quantify and assess the availability of crucial resources such as biomass, water, renewable energy, and geological storage. Carbon Gap’s own Carbon Removal Readiness Assessments (CRRA) have contributed the most to improvements in this regard. Funding for CDR research and innovation has not seen many changes in Europe over the past year, apart for the Netherlands markedly increasing its CDR funding budget.

Carbon Gap’s CRRA reports have significantly contributed to estimating the realistic potential for CDR deployment in Germany, Italy and Poland over the past year. The British government also commissioned a major report on the deployment potential for Greenhouse Gas Removals which has influenced many of the policy developments in the UK. In France, the national CDR association and the consulting firm BCG released a report on the national economic potential of CDR. Whereas in Switzerland, the ACHIEVE consortium was awarded a grant to determine the potential of carbon capture, usage, and storage (CCUS) and CDR in the country.

The Netherlands’ Carbon Removal Innovation Programme launched in December 2025 has centralised and added to existing innovation, research and development funding and subsidies for CDR. A new EUR 10 million R&D subsidy under the Mission-Driven Research Development and Innovation programme was launched for permanent CDR demonstration projects at the end of 2025. The 2026 Climate Fund national budget allocates EUR 50 million to innovation and early scaling of carbon removals starting around Technological Readiness Level 6 in marine CO₂ storage, biochar, bioCCS, DACCS, and mineralisation.

In 2025, Denmark allocated different pools of public funding to support CDR more or less directly. DKK 15 million has gone to the Danish national geological institute to research safe geological CO₂ storage. Furthermore, as part of its research and innovation agreements until 2029, the government has dedicated DKK 37.9 million for monitoring underground CO₂ storage. In 2026, part of the research focus of the DKK 310 million Innovationsfond Danmark for green technology and innovation is on new materials to lower emissions in the construction sector. This allocation potentially covers long-lasting CDR in construction materials like mineralised concrete and timber. In contrast, the UK has discontinued its Timber in Construction Innovation Fund which closed in 2025.

Deployment incentives

Dedicated financial incentives to promote the deployment of permanent and more durable CDR have multiplied and for the most part expanded across Europe from 2025 to 2026. After nature-based solutions and less durable CDR – which have a much longer history of policy development and funding in Europe – BECCS by far receives the most policy support. There is also some support for DAC and biochar, particularly in Sweden, Denmark, and Switzerland. Ocean-based methods receive more partial forms of support and usually at earlier stages of R&D. Overall, the amount of public funding dedicated to incentivising the deployment of CDR has increased in Europe over the past year.

On August 2025 the British government published their Greenhouse Gas Removal (GGR) Business Model offering Contracts for Difference to de-risk qualifying GGR credits at a given strike price as governed by 15-year private law GGR Contracts. Additionally, the GGR Business Model builds on the CCUS Infrastructure Fund’s (CIF) capital grants in such a way that GGR Grant Fund Agreements can cover up to 50% of upfront capital expenditure requirements for eligible projects. The Power BECCS business model is still under development but is expected to consist of a dual Contract for Difference structure (for low carbon energy, and for GGRs). The support mechanism for large-scale biomass power generators to transition to BECCS is also still under negotiation.

For durable CDR, and BECCS/BECCU pilot projects in particular, Finland introduced a dedicated subsidy fund of EUR 90M (albeit down from EUR 140M in earlier proposals). The government also announced support for the implementation of CCS projects on waste incineration plants by 2030.

The Netherlands has expanded its existing pioneering SDE++ subsidy programme to include DACCS in 2026, while in Sweden the budget for the similarly pioneering BECCS reverse auction fund was reduced by SEK 5 billion (EUR 469 million). However, existing recipients of Swedish state aid did see their due date for delivering negative emissions pushed back by two years.

In Switzerland, since the start of 2025, the ITINERO programme provides funding in part for CCUS and CDR technologies to companies that have drawn up net-zero decarbonisation roadmaps setting out the measures that require additional funding. The revision of the CO₂ Act and the CO₂ Ordinance also enabled companies participating in the ETS to apply for investment subsidies to fund negative-emissions technologies.

The German government is considering potentially developing a domestic purchasing programme for CDR, but there has yet to be official confirmation of what such a programme would entail. Since the Carbon Management Strategy and Potential Act was considerably stalled, no new levers or catalysts for durable CDR have been introduced. Italy currently has no subsidies or deployment incentives specifically for CDR but the country’s National Energy and Climate Plan indicates that Contracts for Difference for CO₂ capture are being developed.

For less-durable CDR, Finland took important steps with its 2025 Forest Growth and Carbon Sink Strengthening Package. The government introduced additional funding through the METKA support system for ash fertilisation on peatlands, increasing the annual target from 11,000 ha to 40,000 ha. The package also announced a new support system for afforestation to be launched on January 1, 2027, as well as updates to monitoring and measurement to incentivise denser forests and longer harvesting rotations. In parallel, the Finnish government is considering developing a carbon payment system to reward increasing carbon sequestration in forestry. Finland’s long-term climate plan also introduces a flexibility mechanism for renewable fuel distributors’ obligation to have a certain share of biofuels. Up to 5.5% of their obligations can now be met by financing other emissions reductions measures such as soil carbon sequestration or feed additives in agriculture. Although this obligation is not entirely dedicated to less durable forms of CDR, it still unlocks more funding and demand for it.

The United Kingdom has decreased its traditional grants towards temporary CDR despite the extension of the Nature for Climate Fund from 2025 to 2026 with a top-up of 400£ million. Indeed, the Environmental Land Management landscape recovery scheme fund which covers some forms of carbon sequestration in land use through its blended finance model was recently reduced from GBP 2.4 billion a year to GBP 500 million while government contracts now include a clause allowing termination within a single year thus drastically increasing uncertainty for project developers. The potential inclusion of woodland credits in the UK ETS could serve to bridge that loss in funding.

Although there have not been policy changes in Sweden regarding deployment incentives for less durable forms of CDR, some may be on the horizon. Over the past year, the Swedish Climate Policy Council called on its government to develop a comprehensive nature restoration plan in particular to enhance soil carbon sequestration through agricultural measures.

The European Union has also announced the development of a Buyer’s Club potentially for both permanent and less durable CDR, and of a Purchasing Facility to support the function of the Club. Whether these proposals constitute a deployment incentive or demand-consolidation instruments remains to be seen as final details are still to be determined.

Enduring framework

A compliance policy generates demand for removals over the long term, such as a CDR obligation on emitters or integrating CDRs into emissions trading. Here, Switzerland has seen significant developments, with the UK setting the stage for CDR integration in its ETS in the coming years. On the other hand, mainstreaming CDR policy involves generating further demand for removals by incorporating a CDR requirement in existing policy instruments. Here Switzerland, Denmark and Sweden have also further embedded CDR into enduring decarbonisation policies. Further incentives to decarbonise and invest in CDR can also be generated by applying carbon prices to sectors outside trading schemes. However, in the past year, across Europe, we have seen quite a few of these applications repealed.

Switzerland is slightly ahead of the UK and of the EU in integrating CDR into its ETS. Indeed, the latest changes to the Swiss ETS from April 2025 integrate geological carbon storage and carbon storage in construction materials (e.g. carbonation in concrete structures) for the purpose of generating carbon credits (for installations already subject to the ETS). The biological storage of captured carbon, through biochar for example, is explicitly excluded however, whether done domestically or internationally. The revenue generated by the ETS will serve to subsidise emissions reductions, CCS, and BECCS projects for those installations that already subject to obligations under the Swiss ETS.

The UK, on the other hand, has decided to integrate Greenhouse Gas Removal allowances into its ETS by 2028, but the inclusion of woodland credits is still up in the air. For its part, the EU is expected to make a decision on the integration of CDR into the EU ETS in July 2026.

Similarly to France’s pre-existing compensation obligation for domestic flights, Switzerland has introduced an obligation for fossil fuel distributors to compensate a certain share of their emissions through emissions reductions projects and CDR. This obligation will increase in 2026, again in 2028, and finally in 2030. These compensation projects will have to be recognised by the Swiss state through the CO₂ Ordinance’s attestations, and at least 12% of compensation projects will have to be domestic.

In 2025, Sweden and Denmark introduced mandatory standards on the climate impact of buildings and construction which would incentivise the use of long-lived carbon products in the sector such as timber and mineralised concrete.

Despite this progress, in 2025, Sweden has continued its trend of cutting some of its admittedly ambitious carbon pricing measures after abolishing its carbon tax on internal flights in July 2025. Similarly, at the end of 2025 the Netherlands scrapped a carbon levy on industry first introduced in 2021. In contrast, Denmark has adopted a specialised CO₂ tax on land-use on carbon-rich soils to be implemented in 2028.

Just governance

Very little progress has been made in Europe to improve the inclusivity of decision-making in CDR policy, to improve the fair distribution of burdens and benefits, or to increase support for research into those topics.

In large part, most of the participatory characteristics of CDR policy-making are generic good governance principles unspecific to CDR and do not represent explicit efforts to garner or measure public support for CDR.

Although policy developments on CCUS infrastructure have touched on issues of fair access, this is largely a question of fairness internal to the CCUS value-chain and less to do with fair burden- or benefit-sharing across society.

Nevertheless, in Finland, the CO2CREATION programme on CDR policy recommendations will include some social and ethical research. A working paper was also published in the UK in the past year on mandatory community benefits associated with CCUS.

As we get closer to 2030 and 2050, and as geopolitical conflicts continue to destabilise the global economy, we are seeing increasing pushback against climate policies and more attempts to weaken them. At the level of the European Union, the failure of the Green Claims Directive, and the Omnibus simplification of the CSRD have stalled any progress on structuring demand signals for CDR across the EU single market. At the national level too, over the past year, we have witnessed cuts to ambitious carbon taxes and climate targets.

Nevertheless, as this report demonstrates, these setbacks have not prevented Europe from continuing to steadily progress towards a coherent set of CDR policies to achieve climate neutrality. In 2026 and 2027, further developments to CDR policy are expected in several key countries and at the EU level. These are laid out in the table below:

Figure 11: Key policy milestones to look out for in 2026

Carbon Gap’s Policy Tracker will be updated regularly to reflect these upcoming changes and to keep you informed of progress on these legislative outcomes.