
By Adeniyi Adeoloye
French President Emmanuel Macron is the latest high-profile figure among a growing number of stakeholders calling for a pause in the implementation of the Article 28 of the European Union (EU) Methane Regulation, joining the United States and a group of EU member states that have already backed a delay.
Barring any postponement, the requirement under Article 28 of the EU Methane Regulation for importers of crude oil, natural gas, and coal sourced from outside the EU to demonstrate and report Monitoring, Reporting and Verification (MRV) equivalence will take effect on January 1, 2027.
The provision seeks to ensure that imported fossil fuels meet the same methane MRV standards as those required of producers within the EU.
Under Article 28, effective January 1, 2027, importers of crude oil, natural gas, and coal from outside the bloc whose “contracts concluded or renewed on or after 4 August 2024” will be required to demonstrate and report MRV measures equivalent to those required within the EU. In contrast, for contracts signed before August 4, 2024, importers are only required to “undertake all reasonable efforts” to ensure the imports are subject to MRV measures established under the regulation.
There are two paths to demonstrating MRV equivalence under the regulation. Producer level and the exporting country level. Regardless of the route chosen, certain conditions need to be met for equivalence to be recognised. Under the producer level route, methane emissions measurement is required at source and site level, and must be verified by a third party. For crude oil and natural gas, monitoring and reporting established at the Oil & Gas Methane Partnership (OGMP) 2.0 level 5 reporting is also considered sufficient to meet the equivalence requirement. OGMP is a United Nations Environment Programme (UNEP) led initiative for methane emissions disclosure and mitigation in the oil and gas industry through a global reporting framework based on direct measurements.
At the country level, equivalence requirement can be met where an exporting country has an MRV regulatory framework that applies to producers and exporters supplying crude oil, natural gas or coal to the EU market and that is at least equivalent to the EU requirement. Such a framework must provide for source and site level quantification, regular reporting, independent verification, effective regulatory oversight, and compliance mechanism.
While the onus is on the importer to provide the required documentation to the competent authority in an EU member state, the underlying information would originate from the producer.
The regulation does not prohibit imports that are not compliant with its requirements. However, such volumes may become subject to fines and penalties.
Whether or not the pause for implementation materialises, African hydrocarbon producers exporting to the EU cannot construe it as a green light for inaction.
For many African producers, the Article 28 requirement and its January 2027 implementation date are not merely an academic exercise. They could become a market access issue, given the substantial exposure of some of the major continent’s major hydrocarbon exporters to the EU market. Any disruption to these trade flows could have implications beyond individual producers, particularly for countries where oil and gas revenues make a significant contribution to government finances.
The degree of exposure, however, varies from country to country. Data from the National Oil Corporation (NOC) of Libya’s 2025 Annual Report Technical and Statistical shows that about 79% of the NOC share of production exports, which reached 342Million barrels in 2025, went to the European market. Of this volume, EU member states received the majority. Italy accounted for 137.6Million barrels (40.2%), France 26.482Million barrels (7.7%), and the Netherlands 22.742Million barrels (6.6%), while Greece, Germany, Romania, Croatia, Sweden, Bulgaria and Poland account for the remainder.
Data from the United Sates Energy Information Administration (EIA) shows that Algeria exported 402,000 barrels per day of crude oil in 2024, of which 73% was shipped to Europe. France accounted for 21% of exports, Spain 12%, and Germany and Portugal 7% each, while the remainder went to other European destination. Algeria exported 1.9Trillion cubic feet (Tcf) of natural gas in 2023, out of which 90% went to Europe. Of this, 672Billion cubic feet was exported as LNG and 1.2Tcf through pipeline. According to the data from the Energy Institute, France received 30% of exports, Italy 12%, Turkey 32%, and the remained was shipped to other European markets.
Data from the Vanderbilt Terminal for Angola’s Oil & Gas Industry shows that EU member states accounted for about 14% of Angola’s 1.05Million barrels per day (BOPD) of crude oil export destination in 2024. Spain led the pack with 45,000BOPD (4.3%), followed by France with 38,000BPD (3.6%), Italy with 35,000BOPD (3.3%), the Netherlands with 18,000BOPD (1.7%) and Portugal with 12,000BOPD (1.1%).
EIA data also shows that Nigeria, Africa’s largest oil producer exported 1.3MillionBPD (1.3MMBPD) of crude oil and condensate in 2024. Of this volume, 622,000BPD (48%) went to Europe. France received 128,000BPD (10%), Spain 153,000BPD (12%), the Netherlands 7%, while 20% was exported to other destinations across Europe.
It can be deduced from the data above that Algeria, Libya, and Nigeria are particularly exposed to the implementation of Article 28, given the share of their hydrocarbon exports that flows to the EU market.
Given the current state of the oil market, particularly in the aftermath of the Russia-Ukraine conflict, and the ongoing tensions between the USA and Iran, it is understandable why some countries and stakeholders are calling for a delay. Perhaps it is not lost on those calling for a pause that the implementation of Article 28 could leave European buyers facing limited supply alternatives, particularly if a significant share of the current import is unable to meet the equivalence requirements. The pertinent question now, is what becomes of the exposure risk to the EU market once the supply constraints created by current geopolitical disruptions begin to ease and there is no postponement of the MRV compliance implementation.
Understandably, the implications of the implementation cut both ways, affecting exporting countries as well as the importing market. This is illustrated by Wood Mackenzie’s research conducted in mid-2025, which found that none of the countries “exporting gas/LNG or crude oil to the EU” currently meets the “country-level equivalence requirements” under the EU Methane regulation. Wood Mackenzie study assumes the producer level equivalence “and the ability of importers to identify the upstream producers” will likely determine the volumes of hydrocarbon that meet the requirements of the EU market. The Wood Mackenzie study further indicates that, under its Default Scenario, the non-compliant volume to the EU market could hit about 43% (4Trillion cubic feet) for natural gas, and 87% (9.8MMBPD) of crude oil by 2027. According to the study, the resulting supply constraints could significantly affect the EU refining industry, tighten fuel markets, and contribute to higher gasoline and diesel prices.
The implications for producers in African countries may not be uniform. However, International Oil Companies (IOCs) are better positioned to meet the MRV requirements, owing to their deeper technical capabilities and the reputational expectations of investors and stakeholders in their home countries. National oil companies and indigenous independent producers may face greater compliance challenge, particularly where in-country regulatory frameworks, technical capacity, and MRV systems are not well developed. Although companies such as Shell, bp, Chevron, ENI, ExxonMobil, Equinor, Azule Energy, NNPC Ltd, Libyan National Oil Corporation, Asharami Energy, and Renaissance Africa Energy Company, all of which operate in Africa, are already members of OGMP 2.0, level 5 compliance remains limited. As the Wood Mackenzie study notes, the “availability of fully verified Level 5 [of the OGMP 2.0] supply remains far below what is needed to meet EU demand” despite OGMP 2.0 being one pathway to meet producer level compliance under the EU methane regulation.
African producers and exporters therefore cannot afford to base their strategy solely on the prospect of a postponement from Brussels. Producing countries need to act. Developing equivalent methane regulations at the national level would create the policy framework needed to drive producer compliance. This, in turn would improve the prospects of achieving both country level and producer level equivalence, provided implementation and enforcement are effectively managed.
Whether Article 28 takes effect as scheduled or temporarily delayed, the direction of its travel is clear. It extends beyond regulatory compliance to one of market access. For African producers and exporters, the challenge is no longer whether to prepare for stringent MRV requirements. Rather, it is how urgently domestic regulatory frameworks, institutional capacity, and compliance systems can be developed and strengthened to remain competitive in a market where methane performance is of growing commercial importance.
Adeniyi Adeoloye, a petroleum geoscientist based in Calgary, is in a postgraduate course on Energy Management at the University of Calgary. An editorial associate of Africa Oil+Gas Report, Adeoloye writes from time to time for this platform and can be reached at adeniyi@africaoilgasreport.com.












You have been running an extended well test in Igbomotoru 2, so what exact volume of crude have you exported, and how much do you have in storage?
Aside from harmonising taxes and agencies, what else can the government do to relieve pressure on new marginal entrants?
Is there anything else you would like our readers to know about BAP Energy that we haven’t covered?



