New 2026 CCUS and Hydrogen Rules for Offshore: What you need to know

On Monday 6 April 2026, the Carbon Capture Utilisation and Storage and Offshore Hydrogen Production (Miscellaneous Amendments) Regulations 2026 came into force, introducing significant changes to offshore health and safety regulation.

The amendments extend the existing regime to offshore carbon capture utilisation and storage (CCUS) activities, including the transport of dangerous fluids in pipelines and offshore hydrogen production.

This insight highlights the current legal framework, explaining the changes, and signposting what these developments mean for emerging CCUS and offshore hydrogen.

Offshore major accident hazard management

The offshore safety and environmental regime as applied to oil and gas projects in the UK continental shelf (UKCS) is decades old and lauded around the world, requiring duty holders to identify major hazards, manage risk, and demonstrate how risks are controlled.

As CCUS and offshore hydrogen projects have developed, gaps have emerged – particularly around pipelines, emergency response obligations and safety case requirements. This has created uncertainty for operators about how offshore safety duties apply to these newer processes.

Updating the framework was essential to ensure the UK offshore safety and environmental regimes effectively encompass, assess and respond to the risks associated with offshore CCUS and hydrogen production. The 2026 regulations effectively integrate CCUS and offshore hydrogen into the existing oil and gas safety case regime, treating dense-phase CO2 pipelines, used for CCUS as major accident hazard infrastructure.

Key legislative changes

The 2026 regulations make a series of targeted updates across the offshore legislative framework, including:

• The Pipeline Safety Regulations 1996
• The Offshore Installations and Pipeline Works (Management and Administration) Regulations 1995
• The Offshore Installations and Wells (Design and Construction) Regulations 1996
• The Offshore Installations (Offshore Safety Directive) (Safety Case etc) Regulations 2015
• The Offshore Installations (Prevention of Fire and Explosion, and Emergency Response) Regulations 1995

Expanded definitions across offshore safety regulations
Key regulatory terms, including ‘operator’, ‘licensee’, ‘associated structure’, ‘offshore installation’, ‘non-production installation’ and ‘production installation’ will be expanded to expressly include CCUS and offshore hydrogen production.

This ensures these sectors are subject to the same duties as oil and gas operations, including:

• Safety case requirements
• Risk control duties
• Major hazard management standards

Major accident and emergency response duties extended to CCUS and hydrogen operations
CCUS and offshore hydrogen operations will have to comply with existing fire, explosion and emergency response requirements. This includes notification duties to the Health and Safety Executive (HSE) and alignment with the UK’s major accident prevention framework.

CO2 classified as a “dangerous fluid”
CO2 transported for CCUS purposes will be formally classified as a ‘dangerous fluid’ under pipeline safety legislation. 

As a result, CO2 pipelines will be subject to full major hazard oversight, including:

• Pipeline integrity management
• Leak detection
• Emergency shutdown requirements

For a CCUS pipeline, this may mean updating leak detection systems to meet pipeline safety requirements.

‘Well’ regulations
Wells used for CCUS will now fall under existing well design and construction requirements.

Duty holders must ensure wells used for CCUS:

• Are designed for expected operational pressures
• Are suitable for the substances and gases involved
• Use appropriate and tested equipment to prevent uncontrolled releases

Safety case requirements
Safety case duties will now apply to CCUS production installations and offshore hydrogen production.

Duty holders will be required to demonstrate, before operations commence, how they will control major accident risks associated with hydrogen and CO2 handling, storage and processing under the updated regime.

Consistent references
To eliminate ambiguity, the amendments insert consistent references to “carbon capture, utilisation and storage” and “offshore hydrogen production” across all relevant regulations.    

Practical preparation and compliance

The changes mean that CCUS developers will need to demonstrate ALARP-style (as low as reasonably practicable) risk management and offshore integrity assurance, supported by formal accepted safety cases, emergency response plans, verification schemes, major accident hazard assessments and incident reporting systems from the beginning of any project. Understanding the requirements and ensuring compliance will help avoid project delays, increased costs, and possible enforcement issues.

The 2026 regulations introduce a clearer legal framework for CCUS and offshore hydrogen projects for investment decisions and demonstrates the longer-term vision and commitment of the UK Government to these core industries. However, as ever, increasing regulation potentially increases costs. The new regulations introduce a layer of management and administration previously not required and crystallise a need for ensuring project teams have the necessary competencies including around CO2 process safety, hydrogen explosion risks, and long- term containment assurance in addition to reservoir integrity and geotechnical monitoring.

What this means for offshore CCUS and hydrogen projects

For organisations operating in or entering the CCUS and offshore hydrogen sectors, the 2026 amendments fundamentally change the regulatory landscape. These activities will now be treated in the same way as mainstream offshore oil and gas operations, meaning duty holders face stricter expectations around hazard identification, emergency response, pipeline integrity and safety case preparation. 

If you are developing or planning offshore CCUS or hydrogen projects, you should expect increased scrutiny from the Offshore Major Accident Regulator (OMAR) and begin aligning your systems, documentation and training with the updated requirements.

The amendments also mean that project timelines, budgets and resourcing assumptions may need to be revisited. Early preparation will help prevent delays once the new regime applies, reduce long term compliance costs, and ensure your organisation can demonstrate a robust approach to major accident risk control from the outset.

Please get in touch with our energy team and offshore safety specialists for more information or support in considering what the changes may mean for any project or development.

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