Client Alert: EPA Extends GHGRP Reporting Year 2025 Deadline to October 30, 2026

While the RY 2025 deadline has been extended, key questions remain about future reporting requirements.

The U.S. Environmental Protection Agency (EPA) issued a final rule on February 27, 2026, extending the deadline for Reporting Year 2025 (RY 2025) Greenhouse Gas Reporting Program (GHGRP) from March 31, 2026, to October 30, 2026. The extension was published in the Federal Register as Final Rule 2026-03995 and became effective immediately on February 27, 2026. This action applies to all 47 GHGRP source categories, including Subpart W (Petroleum and Natural Gas Systems).

Importantly, this final action affects only the RY 2025 reporting deadline. All existing reporting requirements under 40 CFR Part 98 remain in effect at this time. Facilities that are currently subject to GHGRP reporting obligations must continue to collect and prepare data for RY 2025 in accordance with the existing rule.

EPA has indicated that it is evaluating broader revisions to the GHGRP that could significantly reduce or eliminate reporting requirements for many source categories. Those potential changes are not yet final and will require additional notice and opportunity for public comment under the Administrative Procedure Act. We previously summarized EPA’s proposed revisions here.

Based on EPA’s February 2026 fact sheet, the Agency has indicated that if the proposed revisions to the GHGRP are finalized before the October 30, 2026 reporting deadline, the 46 source categories identified in prior rulemaking discussions would not be required to submit a RY 2025 report. EPA’s decision to extend the reporting deadline appears intended, in part, to allow time for those revisions to be finalized prior to the new deadline.

However, until a final rule is published, existing requirements under 40 CFR Part 98 remain in effect. KERAMIDA will continue to monitor regulatory developments closely and will provide updates as soon as EPA clarifies the scope of RY 2025 reporting obligations. In the meantime, facilities should proceed under the assumption that current reporting requirements remain in effect.

If you have questions regarding how these developments may affect your facility, please contact us.