The European Federation of Geologists (EFG) has released a position paper calling for a Modular European Framework for Subsurface Governance, urging the EU to move beyond fragmented, commodity-based regulation of Europe’s underground resources ahead of the upcoming review of the Hydrocarbons Licensing Directive.
Critical raw materials, geothermal energy, carbon capture and storage, hydrogen storage, and industrial minerals all depend on the same geological environment. Yet, each is currently governed by separate legislation, permitting authorities, and regulatory traditions. As demand grows for these resources under the EU’s energy transition and strategic autonomy goals, this fragmentation is increasingly acting as a brake on investment, extending project lead times and creating uncertainty for developers and regulators alike.
Drawing on a broad consultation with its expert community, EFG identifies structural weaknesses in the current system:
- Permitting procedures that require parallel approval from multiple, uncoordinated authorities;
- Inconsistent geological standards and terminology across sectors and Member States;
- Uneven regulatory maturity, with mature sectors like oil and gas benefiting from decades of experience while emerging fields such as CCS and geothermal continue to face uncertainty;
- Limited technical capacity within permitting bodies to evaluate increasingly complex projects.
The paper argues that future governance should be founded on geology rather than individual commodities, since every subsurface project begins with the same underlying questions about geological conditions, uncertainty, and long-term behaviour. Having reviewed three policy pathways, from maintaining the current framework to incremental sectoral reform, EFG puts forward a third option as its preferred approach: a common EU-level framework combining a shared procedural and technical foundation with sector-specific modules. This would establish harmonised terminology and interoperable geodata standards, mandate the involvement of certified professional geoscientists in key technical roles, and introduce a stage-gated, risk-based permitting system that scales requirements to a project’s stage and potential impact, alongside a dedicated mechanism for allocating competing subsurface uses. Member States would retain responsibility for land-use planning, resource ownership, and final permitting decisions.
To support implementation, EFG points to existing models that could inform the framework, including Italy’s single-authorisation PAUR procedure, Croatia’s specialised hydrocarbon agency, and Switzerland’s use of accredited external experts within public decision-making. The paper also underscores the role of professional accountability, highlighting titles such as European Geologist (EurGeol) as a model for mutual recognition across Member States, given their capacity to enforce ethical and disciplinary standards that generic academic qualifications cannot. EFG sets out a phased roadmap for implementation, from short-term benchmarks for digital permitting and common terminology through to the longer-term development of an integrated subsurface competence ecosystem across Europe.
With input from its Panels of Experts on CCS and Hydrogen Geological Storage, Geothermal Energy, and Minerals and their Sustainable Use, EFG’s proposal is offered as a contribution to the upcoming review of the Hydrocarbons Licensing Directive and the implementation of the Critical Raw Materials Act and Net-Zero Industry Act.
Read the full position paper here: https://eurogeologists.eu/go/2026-efg-licensing-position-paper
