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Net Zero In Law. Not Yet in Regulation.

  • Writer: Lori Guetre
    Lori Guetre
  • Jun 30
  • 7 min read

Updated: Jul 5

Seven major economies have legislated net zero. The regulations that would actually deliver it are missing in every one.


We took stock of where fifteen jurisdictions stand, covering 84% of global emissions. Here's the gap, and what closing it looks like.


World map with fifteen jurisdictions highlighted: the European Union, United Kingdom, Switzerland, Norway, Canada, United States, Mexico, Brazil, South Africa, Russia, China, Japan, South Korea, India, and Australia. Together these jurisdictions are responsible for approximately 84% of global greenhouse gas emissions.


The European Union has the world’s most comprehensive emissions regulations. It regulates 100% of its emissions. None of them are on a binding path to geological net zero*.


*A quick word on the standard. Throughout this piece we distinguish between net zero - the shorthand target most jurisdictions have written into law - and geological net zero, the stricter standard that peer-reviewed climate science says is required to actually halt warming (Allen, Weaver, and colleagues, Nature 2025). Geological net zero requires that any residual fossil CO₂ emissions be matched 1:1 by permanent geological storage - not by shorter-duration removals. An incomplete regulation might require emissions to decline without ever requiring them to reach geological net zero, or might require them to reach net zero without ever requiring the residual balance to come from geological storage. Our analysis tests every regulation against the strictest of these three tests - the one science requires.


Table showing, for each of 15 jurisdictions, the reporting year, total emissions in MtCO2e, and the percentage falling into three regulatory buckets: Bucket A (Unregulated), Bucket B (Regulated but no path to Geo Zero), and Bucket C (Path to Geo Zero). Sorted with highest Bucket B coverage at the top. Bucket C is empty in every jurisdiction except Canada, which holds 0.44% - its coal-fired electricity regulations. Bucket B coverage ranges from 100% for the European Union down to zero for Brazil and South Africa, both of which sit at 100% Bucket A.

That's a headline finding from a jurisdiction-by-jurisdiction analysis we just completed, looking at how 15 jurisdictions - together responsible for roughly 84% of global emissions - actually regulate the gases that warm the climate.


We classified every emissions source in every jurisdiction into one of three buckets:

  • Bucket A: Unregulated. No binding national regulation requiring emissions to decline. Pledges, voluntary frameworks, and incentive programs all land here. Pledges are not regulation.

  • Bucket B: Regulated, but with no binding path to geological net zero. Most carbon taxes, emissions trading systems, vehicle CO₂ standards, methane rules, and HFC phase-downs belong here.

  • Bucket C: A binding regulation requiring residual fossil emissions to be matched 1:1 with permanent geological storage on a defined timeline, ramping to 100% by a fixed date. This is the standard the science requires.


Bucket C is empty. Almost.


Across all 15 jurisdictions we analyzed - including the EU, the UK, Switzerland, Norway, Japan, Canada, and the United States - the binding-path-to-zero share is 0%. There is exactly one small exception: Canada's coal-fired electricity regulations, which cover 0.44% of Canadian emissions. One regulation, in one jurisdiction, covering less than half a percent of that jurisdiction's emissions, is the entirety of binding obligation to reduce-and-match-residuals that exists in the world today.


That bears repeating, because these facts are buried in the complexity of dozens of sectors in each jurisdiction and most of the public is unaware. The jurisdictions widely identified as climate leaders all sit in Bucket B. The jurisdictions with the most extensive emissions trading systems all sit in Bucket B. The conclusion is not that the leaders aren't trying. The conclusion is that the standard isn't yet in anyone's statute book.



A closer look


Behind each of the 15 rows above is a full sector-by-sector classification - 262 in total - each sourced to a national inventory and evaluated against the Bucket C criteria. Canada is a useful place to see the mechanism, because it's the only jurisdiction with any Bucket C at all.


The same view exists in the workbook for every jurisdiction - free to download from our Research & Insights page.


Breakdown of Canada's 25 emissions sectors classified into three buckets. Bucket C contains one entry - coal-fired electricity - representing 0.44% of national emissions. Bucket B (about 69%) covers oil and gas production and refining, road transport, gas-fired electricity, heavy industry, coal production, and light manufacturing. Bucket A (about 31%) covers residential and commercial buildings, agriculture, waste, passenger and freight aviation and marine, construction, and forest resources.

The single Bucket C entry is Canada's 2018 coal-fired electricity regulations - a binding performance standard phasing out unabated coal generation. Small in scope, but structurally correct: a defined ramp, a binding endpoint, and geological storage as the pathway for any remaining emissions. The rest of Canada's inventory sits in Bucket A (residential and commercial buildings, most agriculture, waste, passenger and freight aviation) or Bucket B (oil and gas, industrial processes, road transport, gas-fired electricity, HFCs).


The same view exists in the workbook for every jurisdiction.



So what about all those net zero pledges?


Here's where the gap becomes hard to look away from. Seven of the 15 jurisdictions we analyzed have legislated net zero - written it into primary law as a binding statutory commitment:

  1. Canada - Net-Zero Emissions Accountability Act (2021)

  2. United Kingdom - Climate Change Act 2008 amended (2019)

  3. European Union - European Climate Law (2021)

  4. Switzerland - Climate and Innovation Act (in force January 2025)

  5. Australia - Climate Change Act (2022)

  6. Japan - Act on Promotion of Global Warming Countermeasures (revised 2021)

  7. South Korea - Carbon Neutrality and Green Growth Framework Act (2021)


Not one of these jurisdictions has translated that legislated target into sector-by-sector binding regulation reaching zero on a defined schedule with a geological matching requirement. The pledges are real. The mechanism that would deliver them isn't.


The math doesn't add up. You can't reach net zero by 2050 while leaving entire sectors unregulated and others regulated only to "reduce" without a binding end point. The pledge in law is one thing. The regulation that delivers it is a different thing. The leaders have built the first. None has built the second.



Why hasn't anyone closed the gap?


Not because of cost. The Boston Consulting Group’s (BCG’s) analysis estimates that decarbonizing a product adds about 2% to most product prices.  (The same finding can be derived by applying permanent CDR at $200 per tonne as the upper-bound cost of removing today’s product climate footprints.)

 

And BCG and the Cambridge climaTRACES Lab independently arrived at a complementary finding: climate action at 1-2% of global GDP versus a net cost of inaction of 11-27% of GDP, with roughly a tenfold return on investment by 2100. Multiple independent estimates converge on the same conclusion. The price of action is small. The price of inaction is large.


Not because of technology. The IEA Net Zero Roadmap, the Mission Possible Partnership sector reports, and the Goldman Sachs Carbonomics analysis converge on a similar finding: the abatement pathways exist, sector by sector, and are technically viable today. What remains is regulatory codification of pathways that are already commercially viable.


Not because of constitutional impossibility. Several jurisdictions are within a single statutory amendment of getting it done. Canada has the only existing Bucket C regulation - the coal-fired electricity standard in force since 2018 - and extending that template to additional sectors is a concrete legislative move that doesn't require inventing a new framework. Norway hosts the Northern Lights infrastructure, the most developed cross-border CO₂ storage hub in the world, and prices carbon on roughly 90% of national emissions. Switzerland has codified its 2050 net zero target with binding interim milestones and explicit reference to industrial CCS in the federal long-term strategy. The European Union adopted a 2040 climate target of -90% net GHG in March 2026, and the Carbon Removals Certification Framework's first methodology came into force in May. South Korea's Constitutional Court ruled in August 2024 that the jurisdiction's framework climate act is unconstitutional for failing to set binding sector targets between 2031 and 2049 - revised legislation is now in progress.


The first move is the hard one. The second through fifteenth follow more easily. Once the standard is codified anywhere, it can travel into trade agreements, treaty frameworks, and the climate policy of every jurisdiction that doesn't want to bear the trade-adjusted cost of being last.


And within any given sector, progress isn't binary. Sectors don't have to leap from Bucket A to Bucket C in a single move - regulating an unregulated sector is a start, adding a defined reduction pathway to an already-regulated sector is the next step, and extending that pathway to geological net zero completes the arc. Every sector can move forward from wherever it currently stands.



What closing the gap actually looks like


Four things, in roughly this order.


Codify the geological net zero standard. At least one major jurisdiction needs to write the obligation into statute: reduce fossil emissions as far as possible and match any residuals 1:1 with permanent geological storage, with a defined ramp from current coverage to 100% by a fixed date. This is the missing legislative artifact in every jurisdiction we analyzed.

 

Canada recently took a step in this direction with its Request for Standing Offer for permanent carbon dioxide removal to address federal government emissions, requiring a minimum threshold of 1,000 years of storage durability - a precedent for what statutory matching obligations on the broader economy could look like.


Build the abatement-pathway standards underneath. Sector by sector, the technical compliance pathways to “do our best and (permanently) remove the rest” exist and are documented in published roadmaps. The work that remains is regulatory codification.


Set predictable, pre-announced ramps to geological net zero. The certainty of the ramp matters as much as the level of the price. A pre-announced glide path from today's coverage to 100% geological matching by 2050 gives capital the predictability it needs to deploy at scale and helps motivate the buildout of the lowest-cost solutions.


Use Climate Footprint Labels and Carbon Border Adjustments to close the loop. Producers need a level playing field across jurisdictions; consumers need information at the point of decision. Both already exist in pilot or scaled form.


That's it. Not invention. Not breakthrough technology. Not impossible economics. Codification. This is the case for Regulate All Emissions, the fourth of Possible by Design’s four advocacy ideas alongside Climate Footprint Labels, Abatement Pathway Standards, and Geo Zero Products.



What's next


The full jurisdiction-by-jurisdiction analysis is published as a Tech Note alongside the underlying workbook on the Research & Insights page. The analysis is a working public-interest tool, not a static publication - we'll continue updating it as new national inventories are analyzed and as new regulation enters force, and we welcome corrections, additions, and extensions to additional jurisdictions.



What we'd like the reader to leave with: the headline isn't that nobody's done the work yet. The headline is that the work is small, the path is clear, and some jurisdictions are close. But today's math doesn't add up. Let’s get it all out on the table so we can see it and so we know what to do.  


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© Possible by Design, CC BY 4.0.

Contents may be shared and adapted with attribution.

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