Client Alert: EPA Extends RY2025 GHGRP Deadline (Again) to March 2027
/The October 30, 2026 deadline is off the table, and EPA's broader GHGRP rollback still isn't final.
On October 14, 2026, the U.S. Environmental Protection Agency (EPA) published an interim final rule extending the Greenhouse Gas Reporting Program (GHGRP) deadline for Reporting Year 2025 (RY 2025) from October 30, 2026, to March 10, 2027 (91 FR 65112). The rule amends 40 CFR 98.3(b)(6), became effective on publication, and applies to all GHGRP source categories. This is the second extension of the RY 2025 deadline. EPA previously moved it from March 31, 2026, to October 30, 2026, as we reported in our March 2026 Client Alert.
EPA gave two reasons for the new extension. First, the Agency needs more time to consider the more than 50,000 comments it received on its September 2025 proposal to reconsider the GHGRP, and to take final action on that proposal before RY 2025 reports are due. Second, EPA stated it will not have the electronic Greenhouse Gas Reporting Tool (e-GGRT) ready in time for an October 30 deadline. EPA normally opens e-GGRT about six weeks before reports are due. For many reporters, this explains a lot. EPA has not yet released the e-GGRT reporting templates for RY 2025, so companies have been waiting without the tools they normally use to prepare, check, and load their data. Without e-GGRT and its templates, an October 30 deadline was not realistic for either EPA or the regulated community.
EPA's reconsideration proposal would eliminate reporting for 46 source categories and suspend the remaining Subpart W segments until 2034, meaning no facility would need to submit a RY 2025 report if the proposal is finalized as written. The repeated deadline extensions appear intended to let EPA finalize those revisions before any RY 2025 reports come due. The new rule supports that reading: EPA states the extension will let reporters benefit from any burden-reduction revisions it finalizes for RY 2025, and will help them avoid wasted compliance effort.
What this means for your facility
The rule changes only the RY 2025 deadline. All existing reporting, monitoring, and recordkeeping requirements under 40 CFR Part 98 remain in effect until EPA publishes a final rule on its reconsideration proposal. Facilities should keep their RY 2025 data organized and ready to submit, and should continue RY 2026 monitoring and data collection under the current rule.
Facilities should also plan for a potential March 2027 reporting crunch. If EPA ultimately keeps some or all existing obligations, RY 2025 reports would be due March 10, 2027. Under the current rule, RY 2026 reports are due March 31, 2027. That could put two annual reports due within about three weeks of each other.
Because EPA issued this rule without prior notice and comment, it is taking public comment after the fact. Comments are due November 30, 2026, under Docket ID No. EPA-HQ-OAR-2025-0186.
KERAMIDA will continue to monitor EPA's action on the GHGRP reconsideration and will provide updates as they develop. If you have questions about how these developments may affect your facility, please contact us.
