EPA Further Delays 2025 Reporting Deadline for Greenhouse Gas Reporting Program Public Comment DEADLINE November 30, 2026

October 15, 2026

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by Erin Krueger (Ethanol Producer Magazine) The U.S. EPA on Oct. 14 issued an interim final rule to further delay the 2025 reporting deadline for its Greenhouse Gas Reporting Program (GHGRP) to March 10, 2027, as the agency continues to consider repeal of the program in its entirety.

The EPA in March 2025 announce plans to reconsider the GHGRP and in September 2025 released a proposed rule to end the program. A public comment period was open through Nov. 3, 2025. If finalized, the proposal would remove reporting obligations for most large facilities, all fuel and industrial gas suppliers, and CO2 injection sites.

The agency has not yet taken final action on its proposal to cancel the GHGRP. In February 2026, however, the EPA issued a final rule delaying the 2025 reporting deadline for the GHGRP from March 31, 2026, to Oct. 30, 2026. The interim final rule published in the Federal Register on Oct. 14 further extends the 2025 reporting deadline to March 10, 2027. A public comment period on the interim final rule is open through Nov. 30.

Development of EPA’s GHGRP was mandated by Congress as part of the Fiscal Year 2008 Consolidated Appropriations Act. The agency in 2009 released a final rule implementing the program, with data collecting beginning the following year.

The GHGRP currently collects GHG data from 47 source categories. More than 8,000 facilities and suppliers in the U.S. are required to calculate and submit data on their GHG emissions annually. Many ethanol plants and other biorefineries are among the facilities subject to the GHGRP.

In announcing its plans to end the GHGRP, the EPA said its review determined there is no requirement under Clean Air Act section 114(a) to collect GHG emission information from businesses. The agency also said that continuing the ongoing, costly data collection is not useful to fulfill any of the agency’s statutory obligations.

The GHGRP, in part, is used by companies to verify GHG sequestration volumes for the purposes of the 45Q credit for carbon sequestration. For that reason, the attorneys general of Nebraska and Iowa in November 2025 urged the EPA to retain Subpart RR of the GHGRP as an opt-in reporting program that ethanol producers could take advantage of on a voluntary basis.

The U.S. Department of the Treasury and Internal Revenue Service, however, are already preparing for repeal of the GHGPM. The two agencies in December 2025 published interim guidance that aims to help eligible taxpayers claim the 45Q credit if the EPA follows through with its proposal to repeal the program. Treasury and the IRS modified and extended the safe harbor for 45Q in August 2026. READ MORE

Related articles

EPA Further Delays 2025 GHGRP Submissions (J.J. Keller and Associates)
EPA Extends Greenhouse Gas Reporting Rule Deadline (U.S. Small Business Administration Office of Advocacy)
Rulemaking Notices for GHG Reporting (U.S. Environmental Protection Agency)
EPA Pushes Back Deadline for Reporting Greenhouse Gas Emissions (Taxpayers for Common Sense)
Extending the Reporting Deadline Under the Greenhouse Gas Reporting Rule for Reporting Year 2025 to March 10, 2027 (Federal Register)

Excerpt from J.J. Keller and Associates: EPA published an interim final rule on October 14, 2026, further extending the submission deadline for the reporting year (RY) 2025 annual greenhouse gas (GHG) report from October 30, 2026, to March 10, 2027.

Who’s impacted?

The final rule applies to facilities subject to the GHG Reporting Program (GHGRP) at 40 CFR Part 98. Generally, three types of entities must report:

Large industrial sources of GHG emissions that directly emit 25,000 or more metric tons of carbon dioxide equivalent (CO₂e) per year;
Fuel and industrial gas suppliers whose products would result in 25,000 or more metric tons of CO₂e of GHG emissions per year if combusted, released, or oxidized; and
CO₂ injection facilities that inject any amount of CO₂ into the subsurface.

What’s the new deadline?

The interim final rule pushes the submission deadline for the RY 2025 GHG report from October 30, 2026, to March 10, 2027. The delay only applies to the RY 2025 GHG report.

Rule refresher

The GHGRP requirements are based on source categories in the subparts of Part 98. Facilities must report GHG emissions from the previous calendar year for all applicable source categories.

Reporters must use specific methods to calculate GHG emissions, which are detailed in the regulations. Facilities submit the annual GHG report to EPA using the electronic Greenhouse Gas Reporting Tool (e-GGRT).

Key to remember: EPA's interim final rule extends the submission deadline for the 2025 annual GHG report to March 10, 2027. READ MORE

Excerpt from Small Business Administration Office of Advocacy: The EPA has been collecting GHG reporting data for the past 16 years from stationary sources, such as power plants and manufacturing facilities. While this data has been used for past EPA regulatory efforts, it does not have a specific purpose under the Clean Air Act.

In September 2025, the EPA proposed significant changes to the GHG reporting rule and received over 50,000 comments from the regulated community. Extending the compliance deadline will allow the EPA additional time to consider these comments while also ensuring regulated entities are not submitting data under an outdated version of the GHG reporting rule.

Action: The extension is effective October 14, 2026. Read the extension notice and submit comments before the November 30, 2026, deadline. READ MORE

Excerpt from Taxpayers for Common Sense:

The proposed rule is not subtle. It clearly states that the goal of delaying 2025 reporting requirements is to “allow EPA additional time to consider comments on the GHGRP Reconsideration Proposal and to take any final action on that proposal.” This rule is not intended to give operators more time to collect and submit their data; it is to buy time until EPA can officially eliminate the program.

Ending the GHGRP is part of a broader movement to weaken transparency and accountability by dismantling public access to data. EPA claims that delaying reporting requirements “serves the public benefit by reducing risk of harm to regulated entities from inadvertently or hastily reporting erroneous or unnecessary information that could later be made public.” That is serving industry, not the public.

Information is power. GHGRP plays a critical role in helping taxpayers, communities, and policymakers understand what drives our emissions and where reductions are possible. Without it, taxpayers are left to shoulder the financial burden created by emission-intensive industries.

Ending the GHGRP would also severely impact the implementation of federal and non-federal policies and programs. The 45Q and 45V tax credits, for example, rely on GHGRP data to determine eligibility. TCS already has longstanding concerns about the taxpayer costs and lack of oversight with these and other energy tax credits. Repealing the GHGRP would worsen those risks — leaving the IRS with little to no means to verify reported data, essentially rubber stamping any number of projects. And establishing a replacement for the GHGRP would be a major financial and administrative challenge.

The cost to industry of complying with a patchwork of federal, state, and international systems could exceed the current costs of GHGRP compliance. Repeal would also create regulatory uncertainty that discourages long-term planning and investment, penalizing companies that acted in good faith and have already invested in the systems and personnel needed to meet GHGRP reporting requirements.

Eliminating GHGRP would create additional costs for taxpayers, communities, and industry. It is the only comprehensive, facility-level dataset of greenhouse gas emissions in the U.S. and an essential tool for transparency, accountability, and sound fiscal governance. This latest rule to delay reporting requirements is just another step towards its end. READ MORE