2026 EPA and OSHA Compliance Deadlines: The Rolling Federal Calendar
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2026 EPA and OSHA Compliance Deadlines: The Rolling Federal Calendar

The maintained 2026 calendar of EPA, OSHA, and DOT reporting deadlines — including the GHGRP extension to October 30, the new TSCA PFAS deadline, frozen federal penalties, and per-agency deadline tables updated quarterly.

by David Harder

Last verified: July 21, 2026 — next quarterly refresh: October 2026. This page is a maintained rolling calendar, not a static January listicle. Bookmark it; the tables below are re-verified against the Federal Register and agency source pages every quarter.

The 2026 EPA and OSHA compliance deadline calendar did something calendars rarely do this year: it changed mid-year, twice. EPA moved the Greenhouse Gas Reporting Program (GHGRP) RY2025 deadline from March 31 to October 30, 2026, and pushed TSCA Section 8(a)(7) PFAS reporting to October 13, 2026. If your facility’s deadline tracker was printed in January, it is now wrong in at least two places — and if you generalized “deadlines are slipping” to your EPCRA filings, it is wrong in a more expensive way. Tier II and TRI dates are statutory. They did not move, and legally cannot.

⚡ In short: March 1 (Tier II, RCRA Biennial), July 1 (TRI Form R), October 13 (TSCA PFAS), and October 30 (GHGRP, extended) are the 2026 anchor dates on the EPA side. OSHA’s cycle ran February 1–April 30 (Form 300A posting) and March 2 (electronic submission). Federal penalties are frozen at 2025 levels — enforcement is not.

The 2026 Federal Compliance Calendar, by Agency

EPA Deadlines for 2026

DeadlineRequirementSource
March 1, 2026EPCRA Tier II hazardous chemical inventory (RY2025) to SERC, LEPC, and fire department — statutory, no extensionsEPA Tier II
March 1, 2026RCRA Biennial Report, CY2025 activity (large quantity generators)EPA Biennial Report
July 1, 2026TRI Form R / Form A (EPCRA §313, RY2025) via TRI-MEweb — 205 PFAS reportableEPA TRI RY2025
July 1, 2026PCB annual document log prepared and maintained on-site — not a submitted report40 CFR 761.180
July 31, 2026TRI voluntary Form R/A revisions close (TRI-MEweb)EPA TRI e-filing
October 13, 2026TSCA §8(a)(7) PFAS reporting, 2011–2022 lookback (most manufacturers/importers)EPA PFAS deadline update
October 30, 2026GHGRP RY2025 annual report via e-GGRT — extended from March 31FR Doc 2026-03995
April 13, 2027TSCA §8(a)(7) PFAS — small businesses reporting solely as article importersFR Doc 2026-07062

Two corrections against older calendars (including earlier versions of this one): there is no “July 15 Annual PCB Report” submitted to EPA — 40 CFR 761.180 requires the annual document log be prepared by July 1 and maintained at the facility — and no TSCA Chemical Data Reporting (Form U) filing is due in 2026. Details on both below.

OSHA Deadlines for 2026

DeadlineRequirementSource
February 1 – April 30, 2026Post Form 300A annual summary in the workplaceOSHA recordkeeping forms
March 2, 2026Electronic submission of CY2025 injury data via the Injury Tracking Application (ITA)29 CFR 1904.41
December 31, 2026Last day the ITA accepts late CY2025 submissions — late filing remains citableOSHA ITA FAQs
OngoingRetain Forms 300 and 301 for five yearsOSHA recordkeeping forms

DOT / PHMSA Deadlines

DeadlineRequirementSource
Before July 1, 2026Renew PHMSA hazmat registration for the July 1, 2026 – June 30, 2027 registration year; carry the certificate in vehiclesPHMSA registration
RecurringHazmat refresher training: DOT every 3 years, IATA every 2 years, IMDG every 3 yearsPHMSA registration

State and Local Deadlines

ItemTimingNotes
Tier II state portal filingMarch 1, mechanics vary by stateEPA maintains the authoritative state-by-state list — several states changed systems; verify your portal every January
Kansas X-ray equipment registration (KDHE)March clusterFiles alongside the Tier II rush for Kansas facilities
Title V semi-annual compliance certificationsPermit-specificFollow your permit dates, not a generic calendar
Tank registrations, stormwater reports, groundwater monitoring, wastewater DMRsPermit-specificDeadlines vary by state and permit — build these from your permit portfolio

Upcoming Deadlines From Today (July 21, 2026)

This is the forward-looking view — everything still ahead of you as of the last verification date, in order.

DeadlineWhat’s RequiredSource
July 31, 2026TRI voluntary Form R/A revisions closeEPA TRI e-filing
October 13, 2026TSCA §8(a)(7) PFAS reports due (most reporters)EPA PFAS update
October 30, 2026GHGRP RY2025 annual reports due (extended)FR Doc 2026-03995
December 31, 2026Last day ITA accepts late CY2025 injury dataOSHA ITA FAQs
February 1, 2027Post Form 300A (through April 30)OSHA forms
March 1, 2027Tier II RY2026 dueEPA Tier II
March 2, 2027ITA electronic submission (CY2026 data)29 CFR 1904.41
April 13, 2027PFAS §8(a)(7) — small article-importer reports dueFR Doc 2026-07062
June 30, 2027PHMSA hazmat 2026–27 registration year ends; renew before July 1PHMSA registration
July 1, 2027TRI Form R RY2026 dueEPA TRI

What Moved in 2026 — and What Legally Cannot

The 2026 story is genuinely two-sided, and both sides matter to how you run your calendar. On one side: EPA extended GHGRP seven months while it reconsiders the program’s future across all 47 source categories, PFAS §8(a)(7) has now been delayed twice (May 2025 and April 2026) with a scope-narrowing proposal still pending, and both OSHA and EPA skipped their annual penalty inflation adjustments for the first time since the 2015 Inflation Adjustment Act regime began.

On the other side: none of that touches statutory dates. Tier II (EPCRA §312(a)(2)) and TRI (§313) deadlines are set by statute — EPA states plainly that it cannot grant Tier II extensions. The facilities that get burned in 2026 are the ones that read the GHGRP headline and concluded deadlines in general are soft. Rule-based dates can move by Federal Register action. Statutory dates cannot, and the enforcement programs behind them are still running.

Can you get an extension on federal EPA reporting deadlines?

It depends on the statute. Tier II and TRI dates are statutory — EPA cannot extend them (EPA Tier II extensions page). Rule-based deadlines can move, and in 2026 two did: GHGRP RY2025 to October 30, 2026, and TSCA PFAS §8(a)(7) to October 13, 2026. Track the Federal Register, not last year’s calendar.

This distinction is the practical filter for every deadline headline you read. If a date is set by statute, no agency press release changes your obligation. If it is set by rule, verify the actual Federal Register document — not a summary — before you touch your tracker, and attach the FR citation when you do.

Did OSHA and EPA penalties increase for 2026?

No. OSHA issued no 2026 inflation adjustment — serious and other-than-serious violations stay at $16,550 and willful/repeat at $165,514 (OSHA memo, May 21, 2026), with the next adjustment opportunity January 15, 2027. EPA is likewise continuing 2025 penalty levels through January 14, 2027 (FR Doc 2026-11585).

Read the freeze correctly: it is a CPI-mechanics artifact of delayed BLS data from the government shutdown, not an enforcement pause — OSHA’s memo frames it exactly that way. Nothing in either document reduces inspection activity or citation authority. Current amounts are posted on OSHA’s penalties page.

What does a missed Tier II or TRI filing cost?

EPCRA §325(c) authorizes civil penalties up to $71,545 per violation per day at current 40 CFR 19.4 levels for §312 (Tier II) and §313 (TRI) violations. Each day of a late filing can count as a separate violation, so exposure compounds quickly even under frozen 2026 penalty levels.

Lesser EPCRA §325(c)(2) items carry up to $28,619 per day under the same table, held at 2025-adjusted levels through the freeze. Late Tier II and TRI filings remain a lead driver of EPA e-Disclosure activity and penalty letters, and TRI has a dedicated compliance and enforcement program. The per-day structure is why a filing that slips three weeks is not a paperwork problem — it is a six-figure exposure calculation.

2026 EPA Reporting Deadlines, Question by Question

When are EPCRA Tier II reports due in 2026?

Tier II hazardous chemical inventory reports for calendar year 2025 were due March 1, 2026, to the SERC, LEPC, and local fire department. The date is statutory under EPCRA §312(a)(2) — EPA states it cannot grant extensions. The next filing (RY2026) is due March 1, 2027.

Tier II applies to any facility storing hazardous chemicals above thresholds — generally 10,000 pounds, or 500 pounds/the threshold planning quantity for extremely hazardous substances (EPA Tier II program page). Filing mechanics vary by state: portals, fees, and state-specific forms all differ, and several states changed systems recently. Check EPA’s state-by-state requirements list every January rather than assuming last year’s portal still works. Tier II is the single deadline most facilities miss for exactly that reason.

When is the TRI Form R deadline for reporting year 2025?

TRI Form R and Form A submissions for RY2025 were due July 1, 2026, via TRI-MEweb, with 205 PFAS on the reportable list. Voluntary revisions can be submitted through July 31, 2026. RY2026 forms are due July 1, 2027.

TRI applies to facilities in covered NAICS codes with 10 or more full-time-equivalent employees that exceed activity thresholds for listed chemicals. If you filed by July 1 and have since found an error — a transposed release estimate, a missed PFAS — the July 31 revision window is the clean way to fix it. After that, corrections go through a more visible process, and EPA’s TRI enforcement program reviews data quality, not just timeliness.

What is the new GHGRP reporting deadline for RY2025?

EPA extended the Greenhouse Gas Reporting Program RY2025 deadline from March 31, 2026 to October 30, 2026 (FR Doc 2026-03995, effective February 27, 2026). The extension covers all 47 source categories, including Subpart W, while EPA reconsiders the program’s scope.

A technical correction followed on June 5, 2026. The extension preamble ties the new date directly to the GHGRP Reconsideration Proposal — EPA bought itself time to decide the program’s future before RY2025 reports come due. That makes October 30 a real deadline sitting inside a genuinely uncertain program. We covered what that means for facilities reporting under 40 CFR Part 98 — and why waiting until October is the wrong move — in our earlier analysis of the GHGRP extension. GHGRP applies to facilities emitting 25,000 metric tons CO2e or more per year in covered source categories.

When is TSCA Section 8(a)(7) PFAS reporting due?

Most manufacturers and importers must submit PFAS data for 2011–2022 by October 13, 2026, through EPA’s CDX (EPA deadline update). Small businesses reporting solely as article importers have until April 13, 2027 (FR Doc 2026-07062). The rule reaches companies with no other TSCA reporting history.

This is the biggest net-new federal deadline of 2026, and it is the one most likely to blindside facilities. The rule is a one-time lookback covering any entity that manufactured or imported PFAS — including PFAS contained in articles — in any year from 2011 through 2022. If your company imported coated components, gaskets, or treated textiles a decade ago, you may have a reporting obligation today even if you have never filed anything under TSCA. The deadline has slipped twice already and a scope-narrowing proposal is pending, but as of this verification date, October 13 stands. Plan against the published date, not the possibility of another delay.

When is the RCRA Biennial Report due and who has to file?

Large quantity generators file EPA Form 8700-13A/B by March 1 of every even-numbered year — the March 1, 2026 report covered CY2025 activity; the next is due March 1, 2028. Facilities that were LQGs in any month of the reporting year are captured.

That last clause is the trap: episodic generation counts. A facility that ran one large cleanout in March and generated over 1,000 kg of hazardous waste that month files as an LQG for the cycle, even if it operated as an SQG the other eleven months. Separately, small quantity generators must re-notify EPA of their generator status every four years — a quiet requirement that does not arrive with a reminder letter.

Is a TSCA CDR (Form U) report due in 2026?

No. Chemical Data Reporting runs every four years; the next submission period is 2028, covering chemicals manufactured or imported during 2024–2027. Manufacturers should be collecting production-volume data now — 2026 is a data-capture year, not a filing year.

Older calendars — including a prior version of this one — listed a September 30, 2026 Form U deadline. That is incorrect. The volumes you produce and import this year fall inside the 2028 reporting window, so the production records and import documentation you build now determine whether the 2028 filing is a records pull or an archaeology project.

2026 OSHA Recordkeeping Deadlines, Question by Question

When must OSHA Form 300A be posted and electronically submitted?

Form 300A must be posted in the workplace February 1 through April 30 each year (OSHA recordkeeping forms). Covered establishments must also submit it electronically through OSHA’s Injury Tracking Application by March 2 (29 CFR 1904.41). Late electronic submissions are accepted through December 31 but remain citable.

The posting and the electronic submission are separate obligations with separate failure modes. A missing 300A posting gets found in the first half hour of any OSHA walkthrough. A missing ITA submission gets found without anyone visiting — OSHA can match employer identification numbers against expected filers (OSHA ITA FAQs). If you missed March 2 for CY2025 data, file now; late beats never.

Which facilities must submit injury data electronically to OSHA?

Establishments with 20–249 employees in designated high-hazard industries, plus establishments with 100 or more employees in Appendix B industries (Form 300/301 data) and larger establishments under 29 CFR 1904.41. OSHA has expanded the covered-industry lists — verify your NAICS against the current rule before assuming exemption.

The Appendix A and Appendix B lists to Subpart E of Part 1904 are not static, and “we weren’t covered last year” is the most common wrong answer in this program. The 100-plus-employee Appendix B tier submits detailed Form 300 and 301 data, not just the 300A summary — a materially heavier lift that needs case-level records in order before March, not during it. Forms 300 and 301 must be retained five years regardless of electronic submission status (OSHA recordkeeping forms).

DOT and Transportation Deadlines

When does DOT hazmat registration have to be renewed?

The PHMSA registration year runs July 1 through June 30. Registrants must renew before July 1 — or before engaging in regulated activity — and fees are not prorated for late registration. Multi-year registrations of up to three years can reduce the administrative load.

The 2026–2027 registration year began July 1, 2026, so a lapsed certificate means you are shipping unregistered right now — and a lapsed registration stops hazmat shipments cold, which costs more in stalled product than the registration ever would. Carry the certificate in vehicles, keep it on file, and pair the renewal with your refresher training tracker.

How to Run This Calendar at Your Facility

Four practical steps, in order of payoff:

  1. Fix the two moved dates. If your tracker still shows March 31 for GHG reporting or omits PFAS §8(a)(7) entirely, correct both today with the FR citations above attached.
  2. Tag every deadline as statutory or rule-based. Statutory dates get zero-flexibility treatment; rule-based dates get a quarterly Federal Register check.
  3. Verify state portals every January. Tier II mechanics change; the federal date does not.
  4. Assign an owner per filing, not per agency. “Environmental handles EPA” is how the PHMSA renewal and the ITA submission fall between chairs.

Running this across EPA, OSHA, DOT, and permit-specific state dates is exactly the kind of standing work that slips when it belongs to whoever is least busy in February. iSi Environmental builds facility-specific deadline calendars mapped to your permits and NAICS codes, and manages the filings themselves for retainer clients — including the quarterly Federal Register verification this page runs on. See our environmental compliance services → or talk to an iSi compliance specialist →.

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