Triangle Energy's collapse: Northern Endeavour 2.0 or a legacy of the pre-reform decommissioning regime?

On 21 July 2026, West Perth based small-cap oil and gas producer Triangle Energy (Global) Limited (ASX: TEG) (Triangle) entered voluntary administration faced with estimated decommissioning liabilities for the Cliff Head oil field and associated infrastructure of $200 million.

Triangle’s entry into administration comes after its junior producer joint venture partner, Pilot Energy Limited (ASX:PGY) (Pilot) entered voluntary administration on 14 July 2026 after failing to secure funding to buy out Triangle’s stake in the joint venture. 

Triangle’s collapse is reminiscent of the infamous Northern Oil and Gas Australia (NOGA) collapse in September 2019 due to the decommissioning liabilities associated with the Northern Endeavour FPSO and associated field infrastructure, the costs and management of which ultimately fell to the Commonwealth Government after NOGA’s liquidation. 

That unprecedented event led to the Federal Government commissioning the Walker Review and implementing various reforms (which came into effect in March 2022) intended to prevent a similar event occurring again. The Federal Government also imposed a levy on the Australian petroleum industry to cover the Northern Endeavour decommissioning costs; a levy which has since raised more than $1.1 billion.  

Triangle's collapse raises questions as to how, despite those reforms, a similar situation has arisen again and who will ultimately bear the cost of decommissioning the Cliff Head oil field.

Background 

Triangle and Pilot acquire the Cliff Head oil field

The Cliff Head oil field was the first commercial oil discovery developed in the Perth Basin. It is located 10 kilometres off the coast of Dongara about 350 kilometres north of Perth.

The oil field was initially developed by the Cliff Head Joint Venture (CHJV), comprising ROC Oil (as operator), AWE Oil, Wandoo Petroleum, ARC and CIECO Exploration & Production. Production first commenced on 1 May 2006.

From 2016, Triangle and Pilot began to acquire the CHJV:

• On 30 June 2016, Triangle announced its acquisition of a 57.5% participating interest (with ROC Oil retaining a 42.5% interest and continuing as operator). This involved acquiring the entities owning AWE Oil’s interests. 
• On 31 March 2017, Triangle announced the purchase of ROC Oil’s remaining 42.5% stake in the CHJV in partnership with Royal Energy Pty Ltd through a 50/50 owned subsidiary company Triangle Energy (Operations) Pty Ltd (TEO). This brought Triangle’s total stake in the CHJV to 78.75%.  A third party was engaged as operator on behalf of the partnership. 
• On 31 May 2021, Pilot announced that it had completed the acquisition of Royal Energy Pty Ltd including its 50% interest in TEO and corresponding 21.25% stake in the CHJV. TEO became operator from May 2021. 

Transitioning Cliff Head to CCS 

On 26 April 2022, Triangle announced the signing of a term sheet with Pilot to restructure their respective interests in the CHJV. The intended purpose was to pave the way for Pilot and Triangle to convert the oil field and associated infrastructure to carbon capture and storage (CCS) after economic oil production ceased. The restructuring would result in Pilot directly owning 60% and Triangle owning 40% participating interest in both the CHJV and the Cliff Head CCS Project

On 27 July 2023, Triangle announced that it had revised the terms of the CHJV restructuring deal with Pilot so that Pilot would instead acquire Triangle’s entire 78.75% stake in the CHJV and become sole owner and operator. The was intended to allow Pilot to move ahead more effectively in converting the oil field to CCS.

Importantly, that transaction was subject to Pilot obtaining sufficient financial security to satisfy the National Offshore Petroleum Titles Administrator (NOPTA) and Triangle that it could assume responsibility for the full decommissioning liability for the oil field in accordance with the Offshore Petroleum and Greenhouse Gas Storage Act 2006 (Cth) (OPGGSA).

The timing for the completion of the term sheet agreement was extended several times but became binding on 2 December 2024. During the intervening period, the oil field ceased production.

Publicly available information suggests that NOPTA approved aspects of the proposed transaction on or about 4 October 2024. However, the precise approval pathway and the material considered by NOPTA are not apparent from publicly available information.

Pilot and Triangle enter administration

Shortly after that time, Pilot’s difficulties began to emerge:

• On 18 December 2024, Triangle announced that it had not received the first payment of $900,000 from Pilot.
• On 17 February 2025, Triangle announced the second payment of $832,912 had also been missed but noted that Pilot continued to fund the oil field operating costs and was pursuing a recapitalisation package to complete the acquisition.
• On 28 March 2025, Triangle announced that it had revised the terms of the sale of Cliff Head’s onshore assets to Pilot. Under the new deal, Pilot would purchase the Cliff Head assets through the issue of a secured promissory note to Triangle with a maturity date of 30 September 2026, effectively converting the debt owed by Pilot to a secured facility. The total price (including interest and ongoing operating costs) was approximately $6.6 million.
• On 14 July 2026, Pilot entered voluntarily administration after failing to secure the required funding or strategic partner in the required timeframe.

On the same day, Triangle announced a trading halt which lasted until 21 July 2026, when it too called in voluntary administrators. In its announcement, Triangle cited its inability to meet its potential decommissioning obligations under the OPGGSA.

What caused Pilot and Triangle to enter administration?

Pilot entered administration because it could not pay Triangle the amounts due under the terms of the promissory note. In June and July 2026, Pilot had also failed to repay a separate $250,000 short term loan from Triangle. 

Since Pilot was unable to purchase the CHJV from Triangle and successfully convert Cliff Head to a CCS project, Triangle was left holding its 78.75% stake in the Cliff Head oil field, which had ceased oil production.

Under sections 270 and 572 of the OPGGSA, titleholders are required to remove infrastructure from the title area when it is no longer being used for authorised operations and prior to surrendering title.

Ultimately, after Pilot failed to acquire the Cliff Head assets from Triangle and convert the oil field to a CCS project (which would have postponed the immediate decommissioning obligations), Triangle became liable for those obligations without the finances required to undertake them.

The NOGA collapse and post-NOGA reforms

An immediate question that arises is how, in the wake of NOGA’s collapse and the subsequent reforms, did another late-life offshore asset with a large decommissioning liability end up being owned by parties unable to meet the costs of decommissioning?

To recap, NOGA acquired the Northern Endeavour FPSO and associated Laminaria and Corallina oil field infrastructure in 2016. The Northern Endeavour FPSO was permanently moored about 550 km northwest of Darwin. The field was originally developed by a joint venture comprising Woodside, BHP and Shell and commenced oil production in 1999.

NOGA entered voluntary administration in September 2019 after the National Offshore Petroleum Safety and Environmental Management Authority (NOPSEMA) shut down Northern Endeavour operations due to maintenance and HSE concerns together with the associated decommissioning liabilities. After NOGA entered liquidation, the Federal Government took ownership and was left with the immense and unenviable task of decommissioning the FPSO and associated oil field infrastructure (which is still ongoing).

In the wake of the NOGA collapse, the Federal Government commissioned the Walker Review into the circumstances which led to NOGA entering administration and to recommend reforms to minimise the risk of a similar event occurring again.

The Walker Review, released in June 2020, concluded that although the offshore regulatory regime included checks and controls to ensure that titleholders decommissioned their assets at the end of the field life:

“…[n]one of the regulatory controls anticipates the circumstances of a titleholder liquidation. This is a serious concern, as such events could be repeated as Australia’s offshore industry matures and late-life assets are likely to be passed from established major oil companies to smaller, less-substantial titleholders.”

Following the Walker Review, a number of reforms to the offshore oil and gas regulatory framework were implemented, including the addition of Chapter 5A of the OPGGSA, which deals with change in control of a registered holder of a title. Most of those amendments came into force on 2 March 2022 under the Offshore Petroleum and Greenhouse Gas Storage Amendment (Titles Administration and Other Measures) Act 2021 (Cth).

While Chapter 4 of the OPGGSA has always dealt with the approval and registration of title transfers, prior to 2 March 2022, section 478 (which requires NOPTA to approve transfers of title) did not require NOPTA to assess whether the resulting titleholder has the financial resources to perform its obligations, including decommissioning, under the OPGGSA.

Further, NOPTA’s scope was previously limited to approving the transfer of title. It did not extend to circumstances where the titleholder remained unchanged but control of the titleholder changed (such as where the titleholder entity is acquired by another company).

Following the amendments to the OPGGSA coming into force on 2 March 2022:

• Sub-sections 478(3A) and 478(3B) now require NOPTA to consider whether the financial resources and technical advice available to the transferee are sufficient to carry out the authorised operations and works and discharge its obligations under the OPGGSA (including decommissioning obligations) before approving a title transfer.

• Chapter 5A extends the same requirements under section 478 to any change in control of the titleholder to be approved by NOPTA.

Additionally, following the Walker Review recommendation to implement trailing liability, the OPGGSA was amended to expand NOPSEMA’s powers to issue directions to undertake decommissioning works and to extend those powers to the responsible Commonwealth Minister.

To this end sections 586 and 587 of the OPGGSA have now been amended to allow NOPSEMA to direct certain parties to undertake decommissioning works, including:  

• Any existing holders of a permit, lease or licence or a related body corporate.

• Any former registered holder of a permit, lease or licence or any person who was a related body corporate at the time it was in force.

In addition, the responsible Commonwealth Minister now has a broad discretion to determine that other related persons could also be the subject of a direction under sections 586 and 587. This potentially includes parties who were jointly involved in operations or were in a position to benefit financially from the title or influence a party’s compliance with their obligations under the OPGGSA.

Why didn’t the Walker Review reforms work in the case of Triangle?

The new trailing liability regime under the OPGGSA provisions apply retrospectively from 1 January 2021. Thus, the parties most closely associated with the development and operation of the Cliff Head oil field during its productive life may fall outside the expanded trailing liability regime, although these reforms and the scope of the related persons provisions are yet to be tested.

While the reforms were designed to prevent the costs of decommissioning falling on taxpayers, Parliament ultimately chose not to extend the regime to all historical titleholders. As a result, where ownership passed through several transactions before 1 January 2021, the practical burden of decommissioning may remain concentrated on more recent owners and their related parties.

In the case of Cliff Head, only Triangle and Pilot and any related bodies corporate appear to be directly caught by these provisions (unless a determination is made to extend the application of these provisions to other related persons). Whether any parties falling within that remit are able to undertake the anticipated $200 million decommissioning works is unclear.    

None of the transactions pursuant to which Triangle, Royal and Pilot acquired their respective interests in the CHJV (which occurred prior to Chapter 5A coming into effect on 2 March 2022) appear to have involved a transfer of title; rather they involved the purchase of the registered titleholder entities and, in the case of TEO, changing the name of the titleholder entity.

By the time the Walker Review reforms came into force, the Cliff Head oil field and associated infrastructure was already wholly owned by Triangle and Pilot, neither of which was likely in a position financially to carry out the estimated $200 million decommissioning obligations for the oil field.

The two transactions which should have attracted scrutiny, if they had been within NOTPA’s remit at the time, were Triangle’s original acquisition of its majority interest in the CHJV in June 2016 and ROC Oil’s divestment of its remaining interest to Triangle and Royal in March 2017. Both of these happened well before NOGA entered administration in September 2019 and the subsequent Walker Review reforms.

It appears that Triangle's collapse, and the current uncertainty surrounding responsibility for the Cliff Head decommissioning, is a consequence of matters which occurred under the pre-reform regulatory regime rather than a failure of the current regulatory regime.

Implications for Oil & Gas Industry 

Shortly after Pilot’s entry into administration, the Federal Resources Minister Madeleine King was reported as saying: “In the event of companies being unable to pay, I will have no hesitation in extending the Northen Endeavour levy or taking other measures to cover all costs for decommissioning”.

The reference to the “Northern Endeavour levy” is a reference to the levy that was introduced under the Offshore Petroleum (Laminaria and Corallina Decommissioning Cost Recovery Levy) Act 2022 (Cth) which came into effect in July 2022. It imposed a levy of 0.48 cents per barrel of oil equivalent produced and will end by 30 June 2030. It was designed to cover the decommissioning costs of the Northern Endeavour and associated fields and to place the cost on the petroleum industry, rather than taxpayers.

It is unclear what the final costs of decommissioning the Northern Endeavour and associated infrastructure will be. If additional funds are needed for decommissioning works, it remains to be seen whether the Federal Government will extend the levy (or apply an additional levy), deploy measures under the trailing liability provisions, and / or introduce other measures or reforms such as extending the retrospective effect of the trailing liability provisions and requiring increased decommissioning security or financial assurances before approving transfers of title or changes in control of titleholder entities.   

Conclusions

Triangle and Pilot’s acquisition of the Cliff Head oil field and its associated infrastructure occurred before the Walker Review reforms and in circumstances where the pre-reform regulatory regime did not provide for adequate regulatory oversight. It remains to be seen whether any other late-life offshore assets acquired by smaller operators under the pre-reform regime will emerge with solvency concerns as production ceases and decommissioning liabilities crystallise.

It may be that the original developers of Cliff Head avoid decommissioning liability in this instance due to limitations on the retrospective effect of the trailing liability reforms. The expanded trailing liability regime however does mean that the regulator is not limited to pursuing Triangle and Pilot (and their related bodies corporate) with respect to decommissioning and may also look to related persons where appropriate.

Companies that have owned, operated or divested offshore assets and infrastructure, their related bodies corporate, and other parties that have derived a direct or indirect benefit from, or exercised influence in relation to, those assets should carefully consider whether they may be the subject of decommissioning directions under the OPGGSA.

Triangle and Pilot’s collapse may cause regulators, financiers and project proponents to scrutinise more closely whether adequate security or funding arrangements are in place to meet both operational and eventual decommissioning liabilities for late-life offshore assets.

The Cliff Head situation may also influence future regulatory treatment of offshore CCS projects. Regulators may increasingly focus on whether proponents have credible long-term funding pathways not only for CCS development and operation, but also for eventual decommissioning should those projects fail to proceed or cease earlier than anticipated.

Should you wish to discuss the issues raised by this article, please do not hesitate to contact the authors.