New rules on reusing offshore installations and establishing CO₂ and hydrogen pipelines

The government says it will seek to create clearer rules for the decommissioning and reuse of existing oil and gas infrastructure, while also expanding the permit regime for pipelines in Danish maritime areas. The bill may be of particular importance for CCS projects, hydrogen infrastructure and companies responsible for decommissioning offshore installations.

On 7 October 2026, the Minister for Climate, Energy and Utilities introduced Bill L 13 to amend the Subsoil Act and the Continental Shelf Act.

According to the government, the bill has two main purposes: to create clearer legal frameworks for the decommissioning and reuse of existing installations, and to expand the permit regime for pipelines on the Danish continental shelf and in Danish territorial waters.

The proposal is a reintroduction of L 108 from the 2025–26 parliamentary session, which lapsed in connection with the general election.

Reuse of existing offshore infrastructure

A significant part of the bill concerns the possibility of reusing installations originally established for, for example, oil and gas production for other purposes.

This is particularly relevant in connection with CO₂ storage, where existing platforms, pipelines, wells and other infrastructure could potentially be incorporated into new projects.

Under the proposed section 33a of the Subsoil Act, reusing an installation for an activity other than the one originally permitted will require the Minister’s approval.

The bill also sets out rules on the transfer of responsibility for such installations.

Following the Minister’s approval, responsibility may be transferred to another licensee that wishes to reuse the installation. The new licensee must have the necessary technical and financial capacity.

It is also proposed that the rules on secondary liability for decommissioning obligations in section 29a of the Subsoil Act apply correspondingly to transfers of responsibility for installations.

As a result, a transfer will not necessarily mean that all previously involved parties are released from future decommissioning obligations.

Stricter rules on decommissioning

The bill also aims to clarify the authorities’ powers in connection with the decommissioning of installations after permits expire or when installations reach their final use.

Under the proposed amendment to section 33 of the Subsoil Act, the Minister must decide how the installations are to be dealt with, including when a permit expires, is surrendered or revoked, or when an installation has served its purpose.

Installations that are no longer expected to be used must, as a general rule, be decommissioned as soon as practicable. A decommissioning project must be approved by the Minister before it is initiated.

New rules for CO₂ and hydrogen pipelines

The bill also expands the permit regime under the Continental Shelf Act.

Where the regime has so far been aimed at pipelines for the transport of hydrocarbons, it is proposed to expand it to cover pipelines for the transport of all types of gases and liquids, including CO₂ and hydrogen.

The change is particularly relevant for future cross-border transport projects and transit pipelines on the Danish continental shelf and in Danish territorial waters.

At the same time, the bill is intended to support Denmark’s obligations under the UN Convention on the Law of the Sea, including the rules on other states’ access to establish pipelines on the continental shelf.

Implications for industry

The bill may create clearer conditions for leveraging existing offshore infrastructure in the green transition.

However, for companies considering taking over and reusing installations for, for example, CO₂ storage, it will be crucial to clarify future obligations relating to operations, maintenance, environmental matters and final decommissioning.

In particular, the rules on transfer of responsibility and secondary liability should form part of the legal and commercial due diligence for such transactions.

For developers of CO₂ and hydrogen pipelines, the expansion of the permit regime under the Continental Shelf Act will likely provide a clearer regulatory starting point for projects involving Danish maritime areas.

The bill is expected to enter into force on 1 January 2027. However, the specific framework for, among other things, reuse, transfer of responsibility and decommissioning will also depend on the terms and more detailed rules laid down pursuant to the Act.

SAAF specialises in advising on pipelines and offshore installations

SAAF regularly advises oil and gas companies, CCS developers, transport operators and investors on the challenges within offshore infrastructure and in connection with the legal aspects of pipelines. We closely monitor developments in these areas. We also maintain strong relationships with both the relevant authorities and commercial project developers, and can advise on both the legal and commercial terms for the projects.