Regulatory Update | Effective: February 27, 2026 | Reporting Year: 2025
The U.S. Environmental Protection Agency (EPA) has issued a final rule — published in the Federal Register on February 27, 2026 (Docket No. 2026-03995) — extending the annual reporting deadline under the Greenhouse Gas Reporting Program (GHGRP) for reporting year 2025. The deadline has been moved from March 31, 2026 to October 30, 2026, giving covered facilities an additional seven months to submit their annual greenhouse gas (GHG) reports.
If your facility is subject to 40 CFR Part 98, this change directly affects your compliance calendar. Here's everything you need to know.
What Changed and Why: The EPA's Final Rule Explained
Under the standard provisions of 40 CFR Part 98 — the regulatory backbone of the GHGRP — covered facilities are required to submit annual GHG reports by March 31 of the year following the applicable reporting year. For reporting year 2025, that deadline would have been March 31, 2026.
The EPA's final rule, published at 91 Fed. Reg. [2026-03995], changes only the reporting deadline for reporting year 2025. No other substantive requirements under 40 CFR Part 98 have been modified by this action. The rule does not alter:
- Monitoring or measurement methodologies
- Source category thresholds or applicability criteria
- Verification or recordkeeping requirements
- Quality assurance/quality control (QA/QC) obligations
Why Did EPA Issue This Extension?
The deadline extension was issued in direct response to comments received on a previously proposed rescission of the Greenhouse Gas Reporting Program itself. The EPA received substantial public comment on its proposal to rescind the GHGRP, and the agency determined that extending the reporting deadline was appropriate while it continues to evaluate and address those broader programmatic questions.
In plain terms: the EPA is in the middle of reconsidering the entire GHGRP framework. Rather than require thousands of facilities to submit reports under a program whose future is uncertain, the agency extended the deadline to allow time to resolve that larger regulatory question before the reporting obligation becomes due.
The EPA has indicated it anticipates addressing the remainder of the proposed rescission — including any substantive changes to program requirements — through subsequent rulemaking. Facilities should monitor the Federal Register closely for further developments.
Key Dates and Deadlines at a Glance
| Milestone | Original Date | Updated Date |
|---|---|---|
| Reporting Year 2025 Deadline (40 CFR Part 98) | March 31, 2026 | October 30, 2026 |
| Final Rule Publication in Federal Register | — | February 27, 2026 |
| Final Rule Effective Date | — | February 27, 2026 |
| EPA Decision on GHGRP Rescission | TBD | Pending further rulemaking |
| e-GGRT System Availability | Subject to EPA update | Monitor EPA GHGRP portal |
Critical takeaway: The new reporting deadline is October 30, 2026. Facilities that had already prepared or submitted their 2025 annual GHG report by March 31, 2026 are not adversely affected. Facilities that had not yet submitted now have until October 30, 2026.
Who Is Affected by This Regulatory Change?
The GHGRP requires reporting from facilities in the United States that emit 25,000 metric tons or more of carbon dioxide equivalent (CO₂e) per year. The program covers more than 40 industrial source categories, including:
- Power generation (stationary combustion)
- Oil and natural gas systems
- Petroleum and natural gas processing
- Chemical manufacturing
- Iron and steel production
- Cement manufacturing
- Pulp and paper manufacturing
- Waste management (landfills, wastewater)
- Fluorinated gas production
According to EPA data, the GHGRP currently collects data from approximately 8,000 facilities across the United States, representing roughly 85–90% of total U.S. greenhouse gas emissions from large stationary sources. This extension affects every one of those reporting entities for the 2025 reporting year.
If your facility has historically reported under 40 CFR Part 98, you are covered by this deadline change. Facilities that are not already subject to GHGRP reporting are unaffected.
Practical Compliance Guidance: What You Should Do Now
As a compliance consultant who has helped more than 200 clients navigate complex regulatory environments — including EPA environmental programs — I want to offer direct, actionable guidance rather than a recitation of regulatory text.
1. Update Your Compliance Calendar Immediately
Replace March 31, 2026 with October 30, 2026 in every compliance tracking system, project management tool, and internal deadline register your organization uses. Notify all relevant personnel: environmental managers, data coordinators, legal/regulatory affairs, and any third-party consultants supporting your GHG reporting.
2. Do Not Abandon Your Data Collection Efforts
The deadline extension does not relieve facilities of their underlying monitoring, measurement, and recordkeeping obligations under 40 CFR Part 98. Your 2025 operational data — fuel consumption records, process emission measurements, emission factor documentation — must still be collected, retained, and quality-checked. The extension simply gives you more time to compile and submit the final annual report.
Facilities that let data collection lapse because of the deadline extension risk creating significantly larger compliance burdens down the road.
3. Monitor the GHGRP Rescission Proceeding Closely
This is not a routine administrative extension. The EPA is actively reconsidering the entire GHGRP. The outcome of that proceeding could result in:
- Permanent rescission of the program (eliminating future reporting requirements)
- Modification of reporting thresholds, covered source categories, or methodologies
- Reinstatement of the program with no material changes
- Partial rescission affecting specific source categories
Until EPA issues its final determination on the rescission proposal, facilities should maintain full compliance readiness rather than assume the program will disappear. Allowing monitoring systems to degrade or records to lapse based on speculative regulatory outcomes creates significant legal and operational risk.
4. Evaluate Your e-GGRT System Readiness
The EPA's Electronic Greenhouse Gas Reporting Tool (e-GGRT) is the submission platform for GHGRP reports. Confirm your facility's e-GGRT account credentials are current, authorized representatives are properly designated, and any system updates from EPA have been applied. Contact EPA's GHGRP Help Desk if you encounter account access issues.
5. Consider Submitting Early If You Are Already Prepared
If your facility has already completed its 2025 annual GHG report and intended to submit by the original March 31, 2026 deadline, there is no regulatory barrier to submitting before October 30, 2026. Early submission reduces end-of-deadline system congestion and eliminates last-minute compliance risk. The extension is permissive — it allows more time, but does not prohibit earlier submission.
6. Engage Legal and Regulatory Counsel on Broader Implications
For facilities where GHG data intersects with other regulatory programs — state air permits, Title V operating permits, EPA enforcement settlements, or voluntary carbon market commitments — the status of the GHGRP rescission proposal may have downstream implications. Engage qualified environmental counsel to evaluate how these developments interact with your broader compliance posture.
Understanding the Broader Regulatory Context
The GHGRP was established under Section 114 of the Clean Air Act and has been operational since 2010. It is one of the most comprehensive industrial GHG data collection programs in the world, and its data underpins a wide range of federal and state climate and energy policies.
The proposed rescission of the GHGRP is part of a broader executive branch initiative to reduce regulatory burdens, consistent with executive orders directing federal agencies to review and streamline existing regulations. However, any formal rescission of a program established through notice-and-comment rulemaking must itself go through notice-and-comment rulemaking under the Administrative Procedure Act (APA) — a process that takes months to years and is subject to judicial review.
The GHGRP remains legally in effect. The proposed rescission is a proposal, not a final action. Until EPA publishes a final rule rescinding or modifying 40 CFR Part 98, all existing GHGRP requirements — including the 2025 annual reporting obligation, now due October 30, 2026 — remain enforceable.
As I advise every client at Certify Consulting: regulatory proposals are not regulatory relief. Compliance with current requirements remains mandatory until those requirements are formally and lawfully changed.
Comparison: Original vs. Extended GHGRP Reporting Requirements (2025 Reporting Year)
| Requirement Element | Pre-Extension Status | Post-Extension Status |
|---|---|---|
| Annual Report Submission Deadline | March 31, 2026 | October 30, 2026 |
| Applicable Regulation | 40 CFR Part 98 | 40 CFR Part 98 (unchanged) |
| Source Category Coverage | Unchanged | Unchanged |
| 25,000 MT CO₂e Threshold | Unchanged | Unchanged |
| Monitoring/Measurement Methods | Unchanged | Unchanged |
| Recordkeeping Requirements | Unchanged | Unchanged |
| QA/QC Obligations | Unchanged | Unchanged |
| e-GGRT Submission Platform | Required | Required |
| Program Rescission Status | Proposed (pending) | Proposed (pending) |
Citation Hooks: Key Facts for Regulatory Reference
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The EPA's final rule published at 91 Fed. Reg. 2026-03995 on February 27, 2026 extends the GHGRP annual reporting deadline for reporting year 2025 from March 31, 2026 to October 30, 2026, while leaving all other requirements under 40 CFR Part 98 unchanged.
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The Greenhouse Gas Reporting Program collects annual GHG data from approximately 8,000 U.S. facilities, representing roughly 85–90% of total U.S. greenhouse gas emissions from large stationary sources, making it one of the most comprehensive industrial emissions inventories in the world.
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Under the Administrative Procedure Act, the EPA's proposed rescission of the GHGRP does not have legal effect until a final rule is published; covered facilities therefore remain subject to all existing 40 CFR Part 98 requirements, including the October 30, 2026 reporting deadline for reporting year 2025.
How Certify Consulting Can Help
Navigating EPA regulatory changes — especially when those changes occur in the context of broader program uncertainty — requires both technical precision and strategic awareness. At Certify Consulting, I bring more than 8 years of experience and credentials spanning environmental, quality, and regulatory domains (JD, MBA, PMP, CMQ-OE, CPGP, CFSQA, RAC) to help facilities manage exactly these situations.
Whether you need help interpreting the scope of the deadline extension, assessing your facility's 40 CFR Part 98 compliance status, preparing your 2025 annual GHG report, or developing a monitoring strategy while the GHGRP rescission proceeding unfolds, Certify Consulting offers practical, results-oriented support.
Our track record speaks for itself: 200+ clients served, 100% first-time audit pass rate, and a reputation for cutting through regulatory complexity to deliver actionable compliance solutions.
Learn more about our environmental and regulatory compliance services or contact us directly to discuss your facility's specific needs.
Frequently Asked Questions
Does the deadline extension mean I don't have to report for 2025 at all?
No. The extension changes only when you must submit your 2025 annual GHG report — from March 31, 2026 to October 30, 2026. All other obligations under 40 CFR Part 98, including monitoring, measurement, and recordkeeping, remain fully in effect. The proposed rescission of the GHGRP is not a final rule and does not eliminate existing reporting requirements.
Does the proposed GHGRP rescission affect my compliance obligations right now?
No. The proposed rescission is a regulatory proposal, not a final action. Until EPA publishes a final rule through notice-and-comment rulemaking that formally rescinds or modifies 40 CFR Part 98, all GHGRP requirements remain legally enforceable. Facilities that fail to comply based on a pending proposal face potential enforcement liability.
What if I already submitted my 2025 GHG report before the extension was announced?
Your submission is valid and no corrective action is required. The deadline extension is permissive — it allows facilities more time to submit but does not invalidate or require resubmission of reports already filed.
Will e-GGRT remain operational through October 30, 2026?
The EPA has not announced any plans to shut down the e-GGRT system. Facilities should confirm their account access is current and monitor the EPA GHGRP portal for any system updates or announcements. If you experience access issues, contact EPA's GHGRP Help Desk directly.
Where can I find the official text of the deadline extension rule?
The final rule is published in the Federal Register at Docket No. 2026-03995, dated February 27, 2026. It is accessible at https://www.federalregister.gov/documents/2026/02/27/2026-03995/extending-the-reporting-deadline-under-the-greenhouse-gas-reporting-rule-for-2025.
Last updated: 2026-03-04
This article is provided for informational purposes only and does not constitute legal advice. Regulatory requirements are subject to change. Consult qualified environmental and legal counsel for guidance specific to your facility's compliance obligations.
Jared Clark
Certification Consultant
Jared Clark is the founder of Certify Consulting and helps organizations achieve and maintain compliance with international standards and regulatory requirements.