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Carbon Counts was invited to the 7th IEA CCS Regulators Network meeting to present initial findings of its analysis on carbon dioxide enhanced oil recovery (CO2-EOR) and emission accounting. The research was carried out for the IEA Greenhouse Gas R&D Programme, with the objective of assessing whether net emissions from CO2-EOR can be accounted for under various policies that support emission reduction projects. Our research focussed on accouting issues for downstream emissions arising from the refining and end-use of the incrementally-produced crude oil. The paper takes the view that this is essentially an emissions leakage problem, and looks at options to address it from that perspective.