The Oil and Gas Authority (OGA) recently launched a consultation seeking views from industry on its revised strategy.

There are several reasons for this revision. From a practical perspective, section 9F of the Petroleum Act 1998 (the Act) provides that the OGA should review the strategy every four years. In addition, the OGA believes that there has been a "fundamental change" in the sector since 2016. The increasing evidence of climate change, together with environmental campaigns and movements, has led to a growing recognition by society that reliance on fossil fuels be reduced. Arguably however, the most significant driver behind the OGA's revised strategy is the UK Government's commitment to achieve net zero greenhouse gas emissions (Net Zero) by 2050.

The strategy is given legislative backing through part 1A of the Act which sets out the "principal objective" of maximising the economic recovery of UK petroleum (MER UK). This has been at the core of the OGA's strategy since 2016 and, whilst still a primary focus, it has been re-positioned in the revised strategy against the backdrop of Net Zero.

The OGA Strategy

In a simple - yet notable - move, the strategy is proposed to be re-named as "the OGA Strategy" rather than the current "MER UK Strategy", adding three principles which cannot be ignored when considering MER UK.

  1. Net Zero
  2. consideration of relevant persons' social licence to operate and develop and maintain good environmental, social and governance practices
  3. compliance with licence and other regulatory obligations.

Central Obligation

The most significant change to the strategy is the addition of a second limb to the principle of MER UK, which aims to bolster the industry's commitment in respect of Net Zero. It means that when pursuing MER UK, relevant persons (e.g. operators) must take "appropriate steps to assist the Secretary of State in meeting the Net Zero target". This places a firmer obligation on North Sea operators to reduce their greenhouse gas emissions (e.g. from flaring and venting and power generation).

Supporting Obligations

The supporting obligations of the proposed strategy aim to demonstrate how the central obligation will apply in different circumstances. The changes proposed largely relate to including reference to Net Zero under the sub-sections of development, asset stewardship, technology and decommissioning. For example, in terms of decommissioning, relevant persons must "be able to demonstrate" that all viable options for the continued use of infrastructure including for re-use or re-purposing for carbon capture and storage (CCS) projects have been "suitably explored". This is a higher obligation than the present strategy imposes and will force operators to actively consider CCS in their decommissioning planning.

Indeed, the importance of CCS is recognised by a completely new section in the revised strategy. This includes relevant persons collaborating with persons proposing CCS projects and allowing access to infrastructure for such purposes on "fair and reasonable" terms.


The price war between Russia and the Middle East has led to a volatile oil price and this uncertainty has been intensified by the ongoing COVID-19 pandemic. Despite these recent crises, the OGA's proposals seek to refresh the strategy (taking into account Net Zero and the importance of CCS) for use over the next four-year period.

The oil and gas industry has a vital role within the UK, and global, economy in maintaining a secure energy supply, providing jobs, engaging in the energy transition, and working towards Net Zero. Nevertheless, Dr Andy Samuel, Chief Executive of the OGA has said that the UK oil and gas industry must go "further and faster" to reduce its carbon footprint. The proposals to revise the strategy certainly appear to be a step in the right direction but will require the support and input from the UK oil and gas industry as a whole.

Responses to the consultation are due by 29 July 2020.