EPA Extended the GHG Reporting Program Deadline to October 30, 2026 — But Do Not Wait
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EPA Extended the GHG Reporting Program Deadline to October 30, 2026 — But Do Not Wait

EPA extended the GHGRP RY2025 deadline from March 31 to October 30, 2026, while simultaneously proposing to eliminate 46 of 47 reporting subparts. Here is what facilities subject to 40 CFR Part 98 need to understand before October arrives.

by iSi Environmental

EPA Extended the GHG Reporting Program Deadline to October 30, 2026 — But Do Not Wait

If your facility reports to EPA’s Greenhouse Gas Reporting Program (GHGRP) under 40 CFR Part 98, you already know the standard March 31 deadline passed without a report due. EPA published a final rule on February 27, 2026 (91 FR 9712) moving the Reporting Year 2025 (RY2025) GHG reporting program deadline to October 30, 2026. That is the new drop-dead date for calendar year 2025 data.

The reason for the extension is not administrative convenience. EPA simultaneously proposed eliminating 46 of 47 GHGRP source categories — and EPA extended the deadline to give itself time to finalize that reconsideration before reports come due. The extension is a holding pattern, not a reprieve.

What follows is a plain-language breakdown of what the extended deadline means, who it applies to, what the enforcement exposure looks like, and what the proposed rollback actually does or does not change for your compliance calendar.

What EPA Actually Did — and Why

The Greenhouse Gas Reporting Program has required roughly 8,000 U.S. facilities and suppliers to report annual GHG data to EPA every March 31 since 2010. The program covers any facility emitting 25,000 metric tons CO2e or more per year from covered source categories, plus fuel and industrial gas suppliers whose products would generate that threshold if combusted or released.

Under the standard rule at 40 CFR 98.3(b), reports covering the prior calendar year are due March 31. EPA amended that provision in February 2026, adding a paragraph that extends the RY2025 deadline to October 30. The legal citation is FR Doc. 2026-03995, docket EPA-HQ-OAR-2025-0186.

The stated reason in the final rule preamble is straightforward: EPA published a broad proposal on September 16, 2025 (90 FR 75810) to permanently remove GHG reporting obligations for 46 source categories. That proposal received more than 50,000 public comments by the November 3, 2025 deadline. EPA needs time to review those comments, develop a final rule, and publish it before asking facilities to spend money collecting and submitting data that the same agency may be eliminating. EPA anticipates finalizing the reconsideration rule around July 2026.

The October 30 window gives EPA roughly three months between a July final rule and the reporting deadline — enough time for facilities to understand their obligations and for EPA to update the electronic Greenhouse Gas Reporting Tool (e-GGRT) system if the rule changes what needs to be submitted.

A correction to the February rule was published June 5, 2026 (91 FR 34161) to fix a typographical error in the regulatory identification number (RIN). No substantive changes. The October 30 deadline stands.

Who Still Has to File by October 30

This is the question every compliance manager is asking, and the honest answer as of June 2026 is: you do not know with certainty until EPA finalizes the reconsideration rule.

Here is the current landscape:

Facilities in the 46 proposed-for-elimination subparts: Under the September 2025 proposal, these facilities would not need to file RY2025 reports at all. This includes most stationary source categories — chemicals manufacturers, cement and mineral producers, iron and steel facilities, pulp and paper, electronics manufacturing, landfills, waste water treatment, and many others. But the proposal is not a final rule. Until EPA signs the final rule, these facilities remain legally obligated under 40 CFR Part 98 as currently written.

Petroleum and natural gas systems (Subpart W): More complex. The proposal retains some Subpart W reporting requirements tied to the CAA § 136 methane emissions charge, but the Big Beautiful Bill (enacted July 4, 2025) amended that provision to delay the waste emissions charge until reporting year 2034. As a result, EPA is proposing to suspend most Subpart W obligations until 2034 as well, with only limited segments retained near-term. The practical effect for most oil and gas facilities: likely no RY2025 report required if the final rule matches the proposal.

Power plants (Subpart D): Power plant GHG data is also used for the Clean Power Plan and other programs. The proposal’s treatment of power plant reporting is worth monitoring closely; the 2025 proposal’s preamble was explicit about CAA § 114 authority, and rescission of the GHG endangerment finding (finalized February 2026) adds additional legal complexity to any continued power plant reporting obligation.

California-regulated facilities: California’s Mandatory Reporting Regulation (MRR), administered by CARB, operates independently of the federal GHGRP. California’s reporting threshold is 10,000 metric tons CO2e per year — lower than the federal 25,000 threshold. California facilities subject to CARB MRR continue to have state-level reporting obligations regardless of what happens to the federal program. CARB’s deadlines are set on a separate calendar. If your facility is in California, the federal extension to October 30 does not touch your CARB obligations.

The Enforcement Exposure Is Not Hypothetical

The GHGRP is enforced under Clean Air Act § 113, 42 U.S.C. 7413. EPA’s civil penalty authority is adjusted annually for inflation under the Federal Civil Penalties Inflation Adjustment Act. As of January 8, 2025, the current figures from 40 CFR § 19.4 Table 1:

  • Judicial civil penalty (CAA § 113(b), 42 U.S.C. 7413(b)): up to $124,426 per day per violation
  • Administrative penalty (CAA § 113(d)(1), 42 U.S.C. 7413(d)(1)): up to $59,114 per day, capped at $472,901 per administrative order

Those are per-day figures. A facility that misses the October 30 deadline by 30 days faces theoretical judicial civil penalty exposure of $3.7 million before EPA has applied any gravity or economic benefit calculation. The per-day enforcement clock does not care about pending rulemakings.

In practice, EPA has historically negotiated GHGRP enforcement settlements in the five-to-six figure range for reporting violations, taking into account good-faith compliance efforts and economic circumstances. But the threat of penalty is real, and the statute is the statute.

The smarter calculation: even if the reconsideration final rule eliminates your subpart, if it is not published before October 30, your existing obligation under 40 CFR Part 98 remains in effect and the deadline holds. “I thought they were going to exempt me” is not a defense.

What the Rollback Proposal Actually Says

The September 2025 proposal is worth reading directly if your facility is in the GHGRP. The summary: EPA is proposing to exercise its CAA § 114 authority in reverse — instead of requiring reporting, it would permanently rescind the regulatory requirement for 46 source categories.

The rationale is rooted in the Trump administration’s deregulatory executive orders: E.O. 14154 (“Unleashing American Energy,” January 20, 2025) and E.O. 14192 (“Unleashing Prosperity Through Deregulation,” January 31, 2025). EPA’s position is that the GHGRP imposes reporting costs not justified by regulatory necessity, particularly for source categories whose data is not directly linked to an active regulatory program. The agency estimated industry compliance cost savings of up to $2.4 billion if the program is ended.

The proposal would leave only the core Subpart W petroleum and natural gas segments in place — and even those largely suspended until 2034. The GHGRP’s 15-year run as a comprehensive GHG database would effectively end.

The Counter-Signal: This Is Not Over

Twenty-four state attorneys general — California, Washington, Colorado, and others — filed comments opposing the proposed rollback. Environmental groups, climate-policy organizations, and academic researchers submitted thousands of the 50,000+ total comments. Several legal theories are in play, including whether EPA has authority under CAA § 114 to retroactively rescind reporting requirements it previously found necessary, and whether the recission of the GHG endangerment finding affects the legal basis for § 114 data collection authority independently.

Litigation is probable if the final rule eliminates the 46 subparts as proposed. A court stay of the final rule could mean reporting obligations are reinstated on short notice — potentially after a facility has already stopped collecting monitoring data.

This is the practical risk that the proposal’s cost-savings framing does not capture: GHG monitoring data is not like a report you can regenerate retroactively. If your facility dismantles its monitoring program in mid-2026 in anticipation of a federal exemption, and a court reinstates the reporting requirement in late 2026 or 2027, your RY2025 or RY2026 data gap is permanent. You cannot go back and re-monitor calendar year 2025 emissions.

Facilities with long investment horizons — particularly those dealing with SEC climate disclosure rules, bank lending covenants that reference GHG data, or voluntary commitments — have additional reasons to keep collecting data regardless of what the federal mandatory program requires.

What Facilities Should Do Before October 30

The compliance path splits depending on where you sit in the regulatory picture.

If your facility is in one of the 46 subparts proposed for elimination: Monitor the EPA rulemaking docket (EPA-HQ-OAR-2025-0186 at regulations.gov) for the final rule. If it is published before October 30 and eliminates your subpart, you likely do not need to file RY2025. If it is not published before October 30, file the report. Do not dismantle your emissions monitoring systems in the interim — maintain the data.

If your facility is in Subpart W (petroleum and natural gas): Legal analysis of the CAA § 136 situation is more complex. The suspension of the methane waste emissions charge until 2034 is relevant, but Subpart W reporting is also used for other purposes. Get a specific compliance determination before deciding whether to file.

If your facility operates in California or other states with independent GHG programs: State obligations are not affected by the federal extension or the reconsideration proposal. Verify your CARB or state program deadlines separately.

For all reporters: Verify e-GGRT account access, designated representative authorization, and facility registration status now — not two weeks before October 30. EPA’s verification process for account changes can take time.

The Bigger Picture for Environmental Compliance Programs

The GHGRP extension and reconsideration proposal are a specific example of a pattern that has played out across the EPA regulatory landscape since early 2025: proposed rollbacks generating legal uncertainty that, paradoxically, creates higher compliance risk for facilities that assume exemption before the rule is final.

The EHS manager or safety director who tracks these regulatory developments in real time — not through industry news summaries published weeks after the fact — is the one who avoids the situation where a missed deadline produces an enforcement notice. That kind of continuous regulatory tracking is exactly what iSi’s COOP retainer is built for. GHGRP clients under the retainer were briefed on the September 2025 reconsideration proposal when it published, and again in February 2026 when the deadline extension rule finalized. The October 30 date has been on the tracking calendar for months. For facilities outside the retainer, this may be the first time they are seeing the full picture.

If your air and GHG compliance program is something you address reactively — after a deadline passes or after an enforcement inquiry arrives — the calculus on iSi’s COOP retainer is straightforward. See the COOP program overview for the specifics on how the retainer works and what the regulatory tracking function covers.

Sources

  1. Federal Register — Final Rule: Extending the Reporting Deadline Under the Greenhouse Gas Reporting Rule for 2025 (91 FR 9712, Feb. 27, 2026): https://www.federalregister.gov/documents/2026/02/27/2026-03995/extending-the-reporting-deadline-under-the-greenhouse-gas-reporting-rule-for-2025

  2. Federal Register — Final Rule Correction (91 FR 34161, Jun. 5, 2026): https://www.federalregister.gov/documents/2026/06/05/2026-11360/extending-the-reporting-deadline-under-the-greenhouse-gas-reporting-rule-for-2025-correction

  3. GovInfo — Official PDF, 91 FR 9712: https://www.govinfo.gov/content/pkg/FR-2026-02-27/pdf/2026-03995.pdf

  4. EPA — What is the GHGRP? (reporter thresholds, facility count, program scope): https://www.epa.gov/ghgreporting/what-ghgrp

  5. EPA — Greenhouse Gas Reporting Program main page: https://www.epa.gov/ghgreporting

  6. Federal Register — Proposed Rule: Reconsideration of the Greenhouse Gas Reporting Program (90 FR 75810, Sep. 16, 2025): https://www.federalregister.gov/documents/2025/09/16/2025-17923/reconsideration-of-the-greenhouse-gas-reporting-program

  7. EPA — Fact Sheet: Reconsideration of GHGRP Proposal: https://www.epa.gov/system/files/documents/2025-09/reconsideration-of-ghgrp-proposal-fact-sheet.pdf

  8. EPA — News Release: EPA Releases Proposal to End Burdensome, Costly GHGRP, Saving up to $2.4 Billion: https://www.epa.gov/newsreleases/epa-releases-proposal-end-burdensome-costly-greenhouse-gas-reporting-program-saving-24

  9. eCFR — 40 CFR § 19.4, Statutory civil monetary penalties as adjusted for inflation (CAA 42 U.S.C. 7413(b): $124,426/day; 7413(d)(1): $59,114/day, $472,901/order): https://www.ecfr.gov/current/title-40/chapter-I/subchapter-A/part-19/section-19.4

  10. California ARB — Mandatory Greenhouse Gas Reporting Regulation: https://ww2.arb.ca.gov/mrr-regulation

  11. eCFR — 40 CFR Part 98, Mandatory Greenhouse Gas Reporting: https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-98