The Nigerian economy is heavily driven by fossil fuels and hydrocarbons, despite its net-zero and decarbonisation targets for 2060. This creates a dilemma, given the difficulty of reducing emissions while existing hydrocarbon infrastructure remains economically significant. Therefore, this article examines the potential role of Carbon Capture and Storage (CCS) as a bridge towards Nigeria’s net-zero ambitions.
CCS as a Bridge — From Capture to Permanent Storage
Carbon Capture and Storage (CCS) involves the use of technologies to capture carbon dioxide (CO₂), a greenhouse gas, with the aim of preventing or reducing its release into the atmosphere. The captured CO₂ is then transported for long-term storage in suitable geological formations, such as depleted oil and gas reservoirs. The CCS process generally involves three interconnected stages: capture, transport, and storage.
1. Capture
CO₂ may be captured from point sources such as power plants and large industrial facilities, including steel, cement, and petrochemical facilities, before it is released into the atmosphere. Depending on the source, different technologies may be used to separate and purify the CO₂ for subsequent transportation and storage1.
2. Transport
Once captured, the CO₂ is conditioned and compressed for transportation from the source to the storage site. Depending on the project, it may be transported through pipelines, ships, or other specialised transport systems2.
3. Injection and Storage
At the storage site, the CO₂ is injected into suitable deep underground geological formations, such as depleted oil and gas reservoirs or saline formations, where it is intended to remain stored over the long term. The storage process also requires monitoring to assess whether the CO₂ remains contained within the geological formation3.
CCS is increasingly considered a potential tool for reducing emissions from emissions-intensive activities. However, its role as a bridge to net zero should not become an excuse for continued reliance on carbon-intensive activities.
Why CCS Matters for Nigeria
CCS is particularly relevant to Nigeria because of its existing hydrocarbon infrastructure and expertise, geological storage potential, and hard-to-abate sectors.
Existing Hydrocarbon Infrastructure and Expertise
Nigeria’s existing oil and gas infrastructure provides a useful foundation for the development of CCS. The Nigerian CO₂ Storage Atlas identifies major concentrations of CO₂ emitters around Lagos, Port Harcourt, Warri and Sapele, which also have existing oil and gas pipeline infrastructure that could potentially support CO₂ transportation. The Atlas further identifies ports and railways as possible complementary transport options4.
Nigeria’s long history of oil and gas exploration also provides an existing body of subsurface data and knowledge that may be relevant to CO₂ storage. This is particularly significant in the Niger Delta, where depleted and near-depleted oil and gas fields have been extensively explored and are supported by drilling, seismic and other subsurface data. The Atlas considers these fields favourable candidates for further assessment because the available geological information provides greater insight into their suitability for long-term CO₂ storage5.
This does not mean that existing oil and gas infrastructure can simply be used for CCS without further assessment. Rather, Nigeria’s existing infrastructure, petroleum experience and subsurface knowledge may help reduce some of the technical and infrastructural barriers to developing a CCS value chain, also subject to an appropriate legal framework and clear implementation modalities.
Geological Storage Potential
Nigeria also has significant prospective geological formations that may support the long-term storage of CO₂. The Nigerian CO₂ Storage Atlas identifies the Niger Delta as having the most favourable storage potential in Nigeria, particularly within its Miocene-age formations. The Atlas identifies both saline aquifers and depleted or near-depleted oil and gas fields as potential storage options6.
The Niger Delta is also significant because of the amount of geological information generated through decades of oil and gas exploration. The Atlas notes that depleted and near-depleted fields in the region are supported by drilling, seismic and other subsurface data, which7 may provide a useful basis for assessing their suitability for CO₂ storage. The Miocene formations were also identified as having the lowest relative geological risk within the Niger Delta.
At the national level, the Atlas estimates a mid-case prospective CO₂ storage resource of approximately 10,700 Gt. This figure, however, represents a prospective resource and should not be treated as Nigeria's established storage capacity. The Atlas states that further assessment, including additional data gathering, well exploration, geological modelling and risk analysis, would be required to mature these resources into usable storage capacity8.
Hard-to-abate sectors
CCS may also be relevant to sectors where emissions are difficult to eliminate through electrification or other conventional decarbonisation measures. Globally, cement, iron and steel, and primary chemical production are recognised as hard-to-abate sectors, with CCS identified among the technologies that may support their decarbonisation9.
This is also relevant to Nigeria. The Nigeria Energy Transition Plan (ETP) identifies cement as the largest industrial emitter and includes the demonstration of CCS projects in the cement industry among its proposed actions10. The ETP also projects the use of biomass with CCS in cement production as part of the longer-term transition pathway.
For Nigeria, therefore, CCS could have a role in reducing emissions from industrial activities where significant emissions may remain even as other cleaner technologies are adopted.
Nigeria’s Emerging CCS Regulatory Framework
Nigeria’s regulatory framework has progressively begun to recognise carbon management and Carbon Capture, Utilisation and Storage (CCUS) activities. The 2023 Midstream and Downstream Petroleum Environmental Regulations require licensees and permit holders to monitor and report greenhouse gas emissions and to submit strategies covering carbon capture, decarbonisation and the achievement of net-zero targets for approval11. The 2025 Midstream and Downstream Petroleum Operations Regulations go further by expressly listing carbon capture, storage and utilisation among activities requiring a licence, permit or authorisation from the Authority12.
This regulatory recognition is also being accompanied by practical CCUS project development. The NUPRC 2024 Annual Report records applications from Indorama and NLNG for CCUS pilot activities. It also notes work towards feasibility studies, data access and the development of CCUS technical guidance for upstream oil and gas13. These developments indicate that CCUS is moving beyond a general decarbonisation objective towards project-level implementation. However, the provisions discussed above do not, by themselves, establish a complete regulatory regime for geological CO₂ storage. Questions concerning storage-site assessment, injection, monitoring, closure, and long-term liability therefore remain important for the commercial deployment of CCS in Nigeria.
Legal Questions for Commercial CCS Deployment in Nigeria
Moving from pilot projects to commercial CCS deployment raises a number of legal questions that existing petroleum and environmental laws may not fully answer. First is regulatory jurisdiction. A commercial CCS project could involve upstream petroleum activities regulated by the Nigerian Upstream Petroleum Regulatory Commission (NUPRC), midstream activities falling within Nigerian Midstream and Downstream and Downstream Petroleum Regulatory Agency (NMDPRA)’s regulatory framework, and environmental approvals under Nigeria’s wider environmental regime.14 Clear allocation of regulatory responsibility across the CCS value chain will therefore be important for project developers.
A second issue concerns access to and use of the subsurface. The Petroleum Industry Act (PIA) 2021 provides a framework for petroleum exploration, prospecting and production through licences and leases15, but permanent CO₂ storage involves a different use of geological formations. This raises questions about the legal basis for accessing storage formations, particularly where depleted or near-depleted oil and gas fields are proposed for CO₂ storage. A legal framework would also need to clarify the licensing and approval requirements for storage sites, including site assessment, injection, environmental assessment, and technical conditions16. Nigeria already has general environmental assessment and petroleum-environmental frameworks, including the Environmental Impact Assessment (EIA) Act and Environmental Guidelines and Standards for the Petroleum Industry in Nigeria (EGASPIN), but these do not by themselves provide the specialised storage-permit architecture found in dedicated CCS regimes.
Finally, the obligations do not end when CO₂ is injected. A credible CCS framework must address monitoring, reporting and verification, leakage and corrective measures, closure and post-closure monitoring, and long-term liability17. These issues are central to the International Energy Agency (IEA)'s CCUS regulatory framework because the risks associated with geological storage may continue after injection has stopped18.
Nigeria also has existing petroleum decommissioning, abandonment and environmental remediation mechanisms under the PIA and its subsidiary regulations, including the 2026 Upstream Petroleum Decommissioning and Abandonment Regulations and the 2024 Upstream Petroleum Environmental Remediation Regulations. However, these mechanisms are not necessarily equivalent to a dedicated regime governing the long-term stewardship of stored CO₂.
Taken together, these issues suggest that the challenge for Nigeria is not simply whether CCS can be authorised, but whether the legal framework can provide sufficient certainty across the entire storage lifecycle, from site selection and injection to monitoring, closure and long-term responsibility. These regulatory questions also have direct commercial implications. Uncertainty over applicable licences, storage rights, monitoring obligations and long-term liability may affect project timelines, costs and the willingness of investors and financiers to support CCS projects. For CCS to move beyond pilot projects, regulatory certainty will therefore be important not only for environmental protection but also for the commercial viability of projects.
CCS and the risk of delaying Energy Transition
CCS can play a useful role in Nigeria’s transition to net zero, particularly where emissions are difficult to eliminate through other means. The technology can reduce emissions from existing industrial and energy infrastructure and may become increasingly relevant where emissions reductions are insufficient to remain within a carbon budget. However, CCS should be viewed as a complementary measure within the energy transition rather than a substitute for reducing dependence on carbon-intensive energy sources19.
CCS is also not a simple or cost-free solution. The technology requires significant investment in capture, transportation and storage, while the legal frameworks adopted in other jurisdictions impose continuing obligations on storage operators, including monitoring, corrective measures, closure and post-closure responsibilities20. This means that continued reliance on CCS to support carbon-intensive activities could result in substantial financial and regulatory commitments, while investment in renewable and other lower-carbon energy sources remains necessary for a broader transition.
For Nigeria, therefore, the value of CCS lies in using it strategically to address emissions that are difficult to avoid while continuing to pursue broader decarbonisation. CCS can serve as a bridge, but the bridge should support the transition rather than become a reason to delay it.
Building a fit-for-purpose Nigerian CCS framework
Nigeria should develop a clear, fit-for-purpose CCS framework that addresses the full storage lifecycle. This should include clear regulatory responsibilities, storage rights and licensing, site assessment and injection approvals, monitoring and reporting requirements, leakage and corrective measures, closure and post-closure obligations, and a clear approach to long-term liability.
In developing this framework, Nigeria can draw from established approaches in jurisdictions such as the United Kingdom, Norway, the European Union, Australia and Alberta, while adapting them to Nigeria’s petroleum industry, geological resources and environmental priorities. The objective should be a framework that provides regulatory certainty without losing sight of Nigeria’s wider energy-transition goals.
Conclusion
CCS can provide Nigeria with a practical means of reducing emissions from existing hydrocarbon infrastructure and hard-to-abate activities while the country continues its wider energy transition. Nigeria’s existing infrastructure, geological potential and emerging regulatory recognition provide a foundation for its development, but commercial deployment will require greater legal certainty around storage rights, permitting, monitoring, closure and long-term liability. CCS can therefore serve as a bridge between Nigeria’s existing hydrocarbon economy and its net-zero ambitions, but the bridge must have a destination.
Footnotes
1. International Maritime Organization (IMO), “Carbon Capture and Storage (CCS)”, available at https://www.imo.org/en/mediacentre/hottopics/pages/carbon-capture-and-storage-(ccs).aspx accessed 24 September 2026.
2. Ibid.
3. Ibid.
4. Nigerian CO₂ Storage Atlas (2025), pp. 11–12, 40–43.
5. Nigerian CO₂ Storage Atlas (2025), pp. 11–12, 136.
6. Nigerian CO₂ Storage Atlas (2025), pp. 11–12, 83–106, 136.
7. Ibid.
8. Ibid.
9. Meng,et al., ‘Technologies and Gaps in Deep Decarbonization of Hard-to-Abate Industrial Sectors’ (2025) 1 Nature Reviews Clean Technology 578–595. 2025). https://doi.org/10.1038/s44359-025-00082-w accessed 25 September 2026.
10. Nigeria Energy Transition Plan, ‘Industry’ (Energy Transition Office), available at https://www.energytransition.gov.ng/industry-sector/ accessed 25 September 2026.
11. Midstream and Downstream Petroleum Environmental Regulations 2023, Part VI.
12. Section 8 (1) (a) (w) of the Midstream and Downstream Petroleum Operations Regulations 2025.
13. Nigerian Upstream Petroleum Regulatory Commission (NUPRC), “Carbon Capture Utilization and Storage (CCUS) Development”, 2024 Annual Report, pp. 60–62.
14. Part III & IV of the Petroleum Industry Act 2021.
15. Section 70, 71 & 72 of the Petroleum Industry Act 2021.
16. Chapter 3, International Energy Agency (IEA), Legal and Regulatory Frameworks for CCUS: An IEA CCUS Handbook.
17. Chapter 4, International Energy Agency (IEA), Legal and Regulatory Frameworks for CCUS: An IEA CCUS Handbook.
18. Ibid.
19.International Energy Agency (IEA), CCUS in Clean Energy Transitions (2020); Intergovernmental Panel on Climate Change (IPCC), Climate Change 2022: Mitigation of Climate Change / AR6 Synthesis Report.
20. Chapter 4, International Energy Agency (IEA), Legal and Regulatory Frameworks for CCUS: An IEA CCUS Handbook.
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