Carbon Management Strategy (CMS) & KSpG Amendment

Germany 2024 Carbon Management Strategy key points plus the Carbon Dioxide Storage and Transport Act (KSpTG, in force November 28, 2025; Bundestag November 6, Bundesrat November 21) mark the end of the 2012 de-facto commercial ban: commercial storage is now permitted on the continental shelf and exclusive economic zone with a uniform pipeline-transport regime, onshore storage only via Land opt-in (none exercised yet), and coal-power emissions excluded from networks and stores. The law answers the EU Industrial Carbon Management Strategy and the Net-Zero Industry Act 50 Mt 2030 injection obligation, but legal commentators note the act precedes any robust CMS, funding framework or social settlement: CCS costs of EUR 130-300/t against ~EUR 90 allowances, unconvinced Länder, crowded EEZ planning and the still-pending London Protocol Article 6 ratification (laws of January 29, 2026) make CO2 export to Norway and Denmark the likely near-term use case.