System and Capacity EnablersREGULATORY SANDBOXES
Lever last updated: 14 September 2026
A supervised real-world trial letting selected organisations test technology outside standard rules.
Cost
Very low to Low
Regulators fund applications, supervision, independent expertise and evaluation. A small programme uses existing staff; several technically demanding trials need dedicated capacity. These are planning estimates, excluding participants' project expenditure.
Complexity
Medium to High
Regulators need trial-selection procedures, safety assessment, monitoring and exit decisions. Where existing powers are insufficient, legislation, coordination between authorities and new technical oversight arrangements add substantial implementation work.
Timeline
Short to Medium
From formal programme design, first supervised trials could begin within one to two years under existing powers, or two to five where legislation and new oversight are needed. These are planning estimates.
Integrity, Transparency & MRV
Innovation & Cost Reduction
Social & Environmental Safeguards
Energy, Transport & Storage Infrastructure
Inputs & Capacity
Demand Formation
Bankability and Cost of Capital
Policy Architecture & Coordination
Overview
Regulators sometimes cannot judge a new technology using rules written for established activities. A regulatory sandbox lets selected organisations run a real-world trial under an agreed plan and close regulatory supervision. The regulator clarifies how requirements apply and, where legally permitted, accepts an alternative way of meeting them or temporarily exempts the trial from a specified rule. For CDR, this could allow testing of a different monitoring approach or new permit conditions. The trial provides evidence for deciding whether and how the activity should operate more widely. Advice or a research test site alone does not provide this regulatory experiment.
Key Considerations
Entry criteria should identify the regulatory problem, the value of testing and why ordinary advice or existing permits are insufficient. Trial plans need named participants, sites, time limits, evidence requirements and clear stop conditions. Regulators must specify which requirements can change and which remain binding, including protections they lack authority to waive. Applicants need sufficient funding to complete the trial, address harm and meet the requirements that apply afterwards. Responsibilities for compensation, site restoration and continuing monitoring should survive the trial where necessary. Data-sharing terms should protect legitimate commercial information while allowing publication of useful findings.
Opportunities
Supervised trials can reveal whether an unfamiliar CDR process can operate safely and whether existing requirements need adapting. Developers learn what evidence approval requires, while regulators observe practical consequences before changing rules for everyone. Testing alternative measurement approaches could improve accuracy or reduce unnecessary compliance costs. Shared findings can help other developers avoid repeating the same work. The main benefit is a better informed route from experimentation to ordinary regulation; wider deployment still requires finance, customers and any necessary permits.
Risks
Inadequate conditions or supervision can expose workers, communities or ecosystems to harm. Selective admission may favour well-connected firms, while confidential findings limit wider learning. Participants may mistake temporary permission for permanent approval, leaving projects unable to continue when the trial ends. Small trials may conceal problems that emerge at scale. Repeated extensions can create preferential treatment or postpone needed reform. Regulatory participation may be misrepresented as government endorsement of a company or its removal claims.
Monitoring and Evaluation
Evaluation should examine the regulatory question, technical performance, compliance costs, incidents and effects on affected communities. Reports need to distinguish what the technology achieved from what the regulatory flexibility changed. Findings should inform a decision to retain, amend or replace the relevant requirement. Follow-up should establish whether participants continued under ordinary rules and whether monitoring or restoration obligations remain outstanding.
Stakeholder Engagement
Discussion should establish the rule creating difficulty and the interests it protects. Applicants explain the proposed test; regulators determine their powers and acceptable conditions. Independent experts assess evidence and safety. Affected communities can shape notification, complaints and stop procedures. Insurers clarify cover for harm, while other market participants can identify unfair entry conditions. Lawmakers need findings where legislation requires amendment.
Governance Levels
National and regional or state regulators can supervise trials and adapt requirements within their statutory powers. Supranational institutions can establish binding arrangements that require national authorities to offer sandboxes, as under the EU Net-Zero Industry Act. Approval must involve the authority responsible for the rule being tested. A municipality needs specific regulatory authority to grant comparable flexibility; hosting a trial does not give it that power. Companies and philanthropies may participate or provide funding, but cannot waive public requirements.
Implementation Strategies
Regulators should identify a regulatory problem, confirm their powers and publish entry criteria that explain the expected public benefit.
Each trial plan should specify activities, any regulatory flexibility, evidence, safeguards, responsibility for harm and conditions for stopping or leaving.
Participants should report against that plan, with independent checks and accessible complaints procedures where risks warrant them.
Regulators should publish useful findings and decide whether the rule should remain, change or permit an alternative, with arrangements for participants after the trial.
Case Studies
European Union Net-Zero Industry Act
The EU's 2024 Net-Zero Industry Act introduced a route for Member States to establish supervised trials of innovative net-zero technologies, including in response to qualifying applications. Its sandbox provisions allow authorities to consider exemptions from national requirements within EU law. Authorities can also adapt supervision without granting an exemption. Trial plans must protect health, safety and the environment, and significant risks can require suspension. The route could help test relevant capture or storage innovations where eligibility conditions are met. It establishes legal machinery for experimentation; it does not itself approve a CDR project or establish that its removals qualify for certification.
Ofgem Energy Regulation Sandbox
Great Britain's energy regulator gave UK Power Networks temporary relief from a connection-charging requirement in June 2021. The Charge Collective project could then use competitive tenders to find the smallest connection-cost discount needed to attract electric-vehicle charging developers. Its evaluation reported that the Norwich tender awarded 46 chargepoints, but the winning bidder required no discount, so the exemption was not ultimately used. The company nevertheless reported that having permission helped the trial and procurement proceed. This energy-sector example shows why evaluation should identify whether regulatory relief was actually needed. An equivalent CDR trial would need its own legal authority and safeguards.
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2–3©2026 Alexander Mäkelä and Carbon Gap.
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Headline and barrier scores based on Carbon Gap analysis.