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.

Client Alert: CARB Releases Multiple SB 253 2026 Reporting Resources for Upcoming November 10th Deadline

On September 1, 2026, The California Air Resources Board (CARB) released multiple resources for the CARB proposed November 10, 2026 greenhouse gas (GHG) emissions reporting deadline, required by Senate Bill (SB) 253. The key update is the introduction of two submittal options for 2026 reporting: a new voluntary Report Intake Platform, and the ability to submit reports and contact information via email. 

New CARB Resources 

• A voluntary 2026 Report Intake Platform that entities may choose to use. Use of this platform is not mandatory. Entities may also email emissions reports and contact information to climatedisclosure@arb.ca.gov. 

• A  Guidance Document for SB 253 2026 Reporting Submittals

• A video tutorial of the voluntary report intake platform

Acceptable Reporting Formats for 2026 

Entities may satisfy their 2026 reporting obligation by: 

• Submitting an existing annual report that includes Scope 1 and Scope 2 GHG emissions. 

• Submitting existing Scope 1 and Scope 2 data already reported to other programs or voluntary initiatives. 

• Using CARB’s Draft Scope 1 and Scope 2 GHG Reporting Template for reporting Scope 1 and Scope 2 data. 

• Submitting a statement of non-reporting (on company letterhead) if the entity was not collecting, and was not planning to collect, Scope 1 and Scope 2 data as of December 5, 2024, when the Enforcement Notice was issued.  

Emissions reports, non-reporting statements, and contact information may be submitted via the voluntary 2026 Report Intake Platform or emailed to climatedisclosure@arb.ca.gov. All emission reports or statements of non-reporting will be made public. 

Key Clarifications 

• Minimum reporting scope: For 2026, reporting entities submitting reports are only required to provide their annual Scope 1 and Scope 2 emissions. Additional details – methodology descriptions, data sources, global warming potential (GWP) values, emission factors, organizational boundaries, disaggregated emissions data by category and gas, and any assumptions used – are optional, not required. 

• Reporting template is voluntary: CARB’s Draft Scope 1 and Scope 2 GHG Reporting Template, posted on October 10, 2025, may be used, but its use is not mandatory for this cycle.  

• CARB will still accept submissions whether or not assurance has been obtained for the 2026 cycle. 

• CARB is currently developing the reporting requirements for 2027, and this guidance only applies to the 2026 reporting cycle. 

California SB 253 Consulting Services

Our team ensures your emissions data meets the rigorous standards of California SB 253 – accurately tracked, reported, and verified.

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Contact

Erica Skowron, MS, LEED GA
Senior Manager, GHG & Sustainability Data
KERAMIDA Inc.

Contact Erica at: eskowron@keramida.com

SBTi Unveils Major Update to Corporate Net-Zero Standard

SBTi published Version 2.0 of its Corporate Net-Zero Standard on June 11, the first major update since the standard launched in 2021.

The update goes beyond adding requirements. How targets are structured, how companies are categorized, and what SBTi expects between validations have changed.

For companies with existing validated targets: no action is required. Your targets remain valid through their defined timeframe.

For new submissions: V2.0 validations open in Q1 2027. Companies may continue submitting under V1.3.1 through January 31, 2028, after which all new submissions must use V2.0.

See SBTi's Summary of Main Changes document.

Livable Cities Update: EPA Releases CPRG Status Report Primer

EPA clarifies CPRG Status Report requirements and expectations for grantees.

The U.S. EPA has released a new Status Report Primer for recipients of Climate Pollution Reduction Grants (CPRG) planning funds, confirming that a Status Report is required at the end of the four-year grant period.

The primer outlines EPA’s expectations for the report and offers recommendations on how jurisdictions can structure it and track implementation progress under their Comprehensive Climate Action Plans (CCAPs).

Key Elements Required in the Status Report

Consistent with earlier CPRG guidance, EPA confirms that Status Reports must include updates on several core CCAP elements, plus one additional requirement, including:

Required

• Implementation status of greenhouse gas (GHG) reduction measures

• Metrics tracking and quantified results for completed measures

• Review of authority to implement measures

• Intersection with other funding opportunities

• Workforce planning progress

• Updated benefits analysis

• Additional Requirement: Identify and outline next steps for CCAP implementation, including near-term projects, timelines, milestones, and associated budget and staffing needs

Encouraged

• GHG inventory updates

• GHG emissions projections and reductions

• Updates to GHG reduction targets

• Implementation narratives providing additional detail on progress

• Updated cost analysis

• Public outreach related to CCAP implementation

These components largely reflect the reporting expectations outlined in the original 2023 CPRG planning grant guidance, which anticipated that the Status Report would provide updates on CCAP implementation and identify next steps.

What’s New in the Primer

While the core requirements remain largely consistent with earlier guidance, the primer provides additional detail on how grantees should approach the report, including:

• Clarification that updates to GHG inventories and emissions projections are encouraged but optional.

• The previously required LIDAC benefits analysis is no longer required for the Status Report.

• Recommended approaches for tracking implementation progress.

• Grantees must report quantified emissions reductions for fully implemented GHG reduction measures using the metrics in their CCAP. Reporting for partially implemented or under-development measures is encouraged but not required. Grantees are also encouraged to update estimated or actual GHG reductions for any measures as needed.

• Guidance on updating benefits analysis and co-pollutant reductions

• Expanded discussion of funding alignment, workforce needs, and implementation barriers

Takeaways and Implications

Implementation tracking will be critical.

The Primer signals that jurisdictions should establish processes to track implementation progress and measurable outcomes throughout the grant period, rather than waiting until the end to compile reporting materials. 

The Status Report is more than a compliance exercise.

EPA emphasizes that the report should be used to communicate progress, adjust priorities, and identify resources needed to sustain climate action beyond the CPRG planning grant period.

Narratives must address progress across all measures. 

Reduction measures will be at varying stages of implementation, making narrative updates essential to clearly communicate progress. All measures must be addressed in the Status Report, including those with limited or no progress, along with explanations and next steps.