Global Trends in Associated Gas Recovery at Sea

Associated gas has traditionally been flared or directly vented in offshore oil and gas production. However, with increasing global attention to methane and SLCPs such as black carbon, associated gas emissions are being brought under rigorous governance targets by various regulatory agencies and international organizations. Companies not early-adopting associated gas recovery/utilization will be subject not only to fines and international market barriers but also forego opportunities to turn waste gas into marketable energy sources, such as mini-LNG, CNG, and gas-to-power. The World Bank’s Zero Routine Flaring by 2030 initiative has become the industry’s action baseline, with dozens of countries and companies signing commitments.

Global Regulatory Landscape

World Bank: Zero Routine Flaring by 2030 (ZRF)

Beginning in 2015, the ZRF asks governments and oil and gas companies to stop “routine” flaring by 2030. As a result, this initiative provides ethical/environmental and international investors and financial institutions project financeability benchmarks. More and more oil companies are integrating this initiative into their group ESG and within their asset valuation..

EU: Methane Emissions Regulation (EU/2024/1787)

The EU adopted the Methane Regulation, or EU/2024/1787, in 2024. It institutes chain-of-effect control over the oil and gas industry, from production to transportation, with increased MRV, necessary LDAR, and control of routine emissions. This regulation applies traceability and enforced transparency to energy products supplied to the European market, indirectly affecting supply chains and trade compliance worldwide.

US EPA: Methane and VOC Control Rules for New and Existing Facilities

Methane and Volatile Organic Compounds (VOCs) regulations were modified in 2023 to 2024 and added to both new and existing sites in the Oil and Gas Industry. This includes new technical and compliance standards. In the Oil and Gas Industry, these new requirements include LDAR (Leak Detection and Reduction), sealing equipment, leak consolidation, and emissions reporting. Companies in North America also operate in the Oil and Gas sector according to the standards set by the United States of America EPA (Environmental Protection Agency) and the details of state-level implementation.

International Maritime Organization (IMO) and Marine-Related Emissions Policies

The IMO’s main focus has always been concerned with ships and vessels, but lately, due to the GHG and air pollution strategies (e.g. the 2023 GHG Strategy and black carbon control advocacy), the organisation has had overlapping impacts on offshore facilities and the vessels operated within the facilities. An example of this is the Emission Control Areas (ECAs) as part of the MARPOL framework and the increased focus on black carbon, as these have increased the mandatory regulations and compliance requirements concerning the offshore regulation of flare gas combustion. Restrictions on black carbon in the Arctic, for instance, are especially stringent.

Key Regulatory Trends

Worldwide Move from Commitment to Penalty-Based Regulation

For the past ten years, the voluntary commitments made to managing associated gas within the global oil and gas sector have been very flimsy. These commitments bring attention to the issue at hand, but as we pointed out, the absence of any consequences leads to minimal reduction of flaring emissions. In the last year, however, the European, US and Canadian markets have legally formalised the ‘ban on conventional flaring’ from a voluntary corporate commitment to a legal responsibility.

For companies, associated gas recovery (FGR), mini-LNG, and gas-to-power will move from ‘optional’ to ‘entry requirements’ and oil and gas products that are unaccompanied by emissions innovations will be very susceptible to the international market’s exorbitant carbon costs.

MRV Becomes the Biggest Compliance Barrier

In the global governance system of methane, one of the greatest transformations is not the capture technology, but rather, the transformation of MRV from optional to mandatory. Under the policies of the EU, the US, and the international banking sector, MRV is now mandatory for oil and gas assets to receive funding, sustain production, and gain access to the global market. This is because methane is a short-lived climate pollutant (SLCP) that has a greenhouse effect 80 times greater than CO2 on the 20-year timescale. Without a standard MRV framework, even if companies utter the phrase ’emission reductions,’ no regulator can ascertain the truth of the matter, and the claims become worthless. Furthermore, units of ’emission reductions’ cannot be used for any policy or market choice.

In the case of offshore associated gas recovery projects, the impact of MRV is even more direct. Without measurement, there are no reductions in emissions, and without MRV, the project remains non-compliant. The volume of emission reductions, the ROI, and the availability of green funds for associated gas recovery systems are all a function of the quality of the data. Hence, there is significant demand for modular, synchronous, online, and real-time monitoring systems on offshore oil and gas production facilities.

Chargeable regulatory concerns will evolve from assessing “does the platform have a flare” to “can the company provide proof that the flare is only used during emergencies.” This represents a new phase of global associated gas regulation focused on MRV and defined by measurement and reporting, verification, and accountability.

Compliance Requirements from IMO, ECA, and Others

Regulating shipping by sea and air transport is the core function of the International Maritime Organization (IMO). However, owing to the recent climate policies, the Organization has been experiencing what has been termed by scholars as “cross-regulatory effects” from offshore oil and gas, especially black carbon, GHG intensity, EEXI/CII, and limits on emissions from Arctic shipping.

With offshore oil and gas platforms, though not ships by themselves, the total complementary transportation fleet is to some extent fully in the hands of the IMO. Those include FPSOs, FSRUs, LNG shuttle tankers, and OSVs, all of which are to comply with MARPOL Annex VI, EEXI, and CII requirements. These regulations impose measures on related vessels aimed at reducing fuel and emission intensity, which in turn compels the platforms to reduce flaring and improve energy efficiency. Recovery of the associated gas is not only environmentally benign since it is used for fuel for the ship (LNG/CNG/gas-to-power) as it reduces black carbon emissions from flaring, which is a fuel a platform has to supply to the vessel.

Among other things, the black carbon communications and guidelines being developed by the International Maritime Organization (IMO) and the Arctic Council Black Carbon Action Plan are a direct result of the IMO’s work and the recently completed report of the Arctic Council’s Grounding Black Carbon in the Arctic Review Black Carbon in the Arctic Working Group. Black carbon is a relatively new and short-lived climate pollutant (SLCP) that has a disproportionate effect on the warming of the Arctic. Because of this, the IMO along with the Arctic Council is working towards prohibiting high sulphur fuel oil and concurrently, the IMO is working towards prohibiting high sulphur fuel oil and restricting emissions along specific Arctic shipping routes. Because flaring is a significant source of black carbon emissions, this means that the flaring of emissions from offshore oil and gas platforms will most probably become subject to the IMO’s black carbon regulations, thereby entering the International Climate Governance.

At this point, regional ECAs (Emission Control Areas) are widening. Northern Europe, North America, and the Mediterranean are regions with ongoing deployments of ultra-stringent regulations on sulphur, NOx/SOx and PM and energy efficiency. Offshore platforms operating in these regions are usually compelled to reduce flaring, recover more associated gas, and clean power to ensure that the vessels meet the regional environmental standards. They are also compelled by the off-control regulations on gas combustion.

To sum up, the NO does not regulate the offshore oil and gas platforms directly, but the IMO’s climate and emissions regulations are increasingly tightening the compliance noose on the platforms’ combustion emissions, associated gas (AG) regulatory control and energy efficiency due to the “related ship → platform operation” interaction.

Technical Path and Feasible Solutions

Technology Pathway	Applicable Scenarios	Technical Highlights / Implementation	Regulatory / Compliance Correspondence
Flare Gas Recovery (FGR)	Medium to high flaring platforms (long-term routine flaring)	Compression recovery → reinjection or supply to fuel systems (gas-to-power, drive compressors) → if sufficient volume, route to liquefaction (mini-LNG) or CNG export; hybrid solutions ensure 70%–95% recovery under varying operating conditions	Complies with EU/US routine flaring bans; supports MRV reporting and carbon reduction certification
Mini-LNG / Micro-LNG (Small-scale liquefaction)	Remote offshore areas without pipelines, low to medium gas production FPSO / marginal wells	Modular skid-mounted design; liquefy associated gas → transfer to small LNG vessel for onshore delivery; generates revenue and meets “no routine flaring” requirements	Complies with EU Methane Regulation restrictions on routine flaring; enables marketable natural gas supply
Gas-to-Power / Gas-to-Fuel	Gas volume insufficient for liquefaction but stable	Associated gas drives internal combustion engines or gas turbines → power the platform or compressors; substitutes purchased fuel, reduces venting/flaring	Supports MRV data collection; reduces carbon emissions; compliant with EU/US regulations
Gas Injection / Reservoir Management	Suitable geological conditions for reservoirs	Reinject associated gas into the reservoir → improves recovery, reduces emissions; requires high-performance injection equipment and long-term monitoring	Reduces emissions; supports long-term compliance and carbon reduction plans; MRV data recording required
LDAR & Methane Online Monitoring (MRV)	All platforms and associated gas projects	Utilize OGI (Optical Gas Imaging), FTIR, Differential Absorption Spectroscopy, UAV inspections, and online sensor networks; data can be recorded on-chain or third-party verified	Fully meets EU/US MRV requirements; ensures transparent, verifiable emissions; supports green financing and international market access

Corporate Compliance Roadmap

To ensure oil and gas platforms comply with global methane regulation and MRV requirements (such as the EU Methane Regulation and the US EPA Methane Rule) and realise associated gas resource recovery benefits, companies should follow this systematic roadmap:

Setting up the Compliance and Project Teams

In order to achieve departmental learning right from the start and integrate the functions of the operation, engineering, finance, and regulation, companies should set up cross-discipline teams comprising operation, engineering, environment/safety, finance, legal, and outside specialists (third-party MRV and auditing). Responsibilities can be allocated so that operations provides actual platform operational data and operational assistance, engineering studies propose technical solutions and installation pathways, environment/safety examines emission risks and compliance standards, finance carries out investment estimation and cost-benefit analysis, while legal and consulting support. This way, MRV data collection, implementing LDAR and developing a Flare Reduction Plan (FRP) will all be conducted within the compliance of the law.

Setting Emission Measurements and Risk Assessments

It is equally necessary to measure and record all emissions data related to venting, flaring, and fugitive emissions by source to build a foundational layer of scientific data to help quantify the platform’s emissions. From these data, annual and instant emission measurements should be developed that focus on methane (CH₄, tons/year), CO₂ equivalence, black carbon, and other significant climate metrics. These data should be combined with risk assessments of high-emission sources, leakage risk points, and regulation-sensitive zones. This combined data will help determine how to invest operationally to reduce platform emissions by looking at historical data and operational flare usage to determine how frequently and patterned flares are used. This also creates foundational data for the EU and US MRV, and other financial institutions that will help with these emissions measurements and with compliance and financing thereafter.

Create and Send in a Flare Reduction Plan

In order to define the roadmap to complete the plan and set the economic viability of the plan, the company must develop a plan in stages: The first stage focuses as a priority in the short term will be the repair of the leaks and the implementation of LDAR, in the second stage which corresponds to the middle term will be the installation of FGR and/or gas to power system and in the last stage the long term solutions will be mini LNG, a pipeline, re-injection, etc. Also, the economic analysis and risk mitigation must be worked on, such as CAPEX, OPEX, IRR (ROI), and risk mitigation. The complete plans need to be delivered to the regulatory agencies to be filed in order to be compliant with the local requirements and global agreements. The FRP is a mandatory formal emission reduction plan to be compliant with different regulations such as EU Methane Regulation and the US EPA Methane Rule, which makes it a necessity.

Initial Implementation of Systems of a Modular Nature

In a bid to ascertain technical feasibility without the risk of investing heavily, firms prefer to deploy modular skid-mounted systems like mini-LNG liquefaction units or Flare Gas Recovery (FGR) units at marginal wells or sites with moderate production levels, which are then closely located to container/unloading facilities. Pilot projects help ascertain the production of associated gas, the recovery rate, the energy loss, and the efficiency of the system so that operational experience can be built, the recovery efficiency at varying operational conditions (usually in the range of 70–95% and requiring project specific validation) can be ascertained on a large scale. Also, this ‘pilot’ process validates the MRV (Modular Gas Reduction) system to help reduce conventional flare gas emissions as required by regulations.

Setting Up an MRV and Third-Party Verification Mechanism

Companies need to use approved measurement and monitoring technologies to support the financing value of emission reduction data and to ensure that data presented on emissions reduction is verifiable and disclosable and includes OGI, FTIR, drone, and network string sensors. While a third party needs to verify a few of the indicators to ensure the data can be trusted, the data can be used for various reporting purposes to regulators and to inform external international buyers and financial institutions market certification for voluntary carbon/methane emission reduction. This can be achieved while meeting international standards such as EU MRV, US EPA, and the World Bank/OGMP 2.0.

The Path to Commercialisation and Financing

The most effective approach for companies engaged in gas recovery is not only to remain compliant with investment regulations but also to obtain a gas recovery and the potential for further positive economic gains while managing investment recovery risks. Companies can utilise a variety of potential business strategies, including the adoption of technology licensing, engineering procurement and construction (EPC) strategic partnerships, operational management (O&M), and equity co-investment with local state-owned enterprises or financial institutions. At the same time, the World Bank and other multilateral development banks also consider and incorporate financing and guaranteed methane and voluntary carbon markets that are compliant with and meet carbon standards. Therefore, an investment can be evaluated through an internal rate of return (IRR) and, with risk-sharing, sustainable value can be gained in the long term alongside equity of risk. Compliance with MRV and Flare Reduction Plan (FRP) schemes not only enables market partnerships to adhere to regulations for financing but also supports project designs that make financing viable.

Conclusion

Regulation and the market have moved from ‘putting up with emissions’ to ‘putting on the demands of reduction and transparency’. For offshore oil and gas operators, associated gas recovery has moved from optional, environmentally virtuous, to a strategic, non-optional, blended, compliance, costing, and business opportunity. Through graduated pilots, unyielding MRV, and collaborative alliances with finance/tech, operators can convert regulatory strangles into long-standing asset value and new lines of compliance.