EPA extended the RY2025 GHGRP annual filing deadline from March 31 to October 30, 2026, through an interim final rule. The interim final rule applies to every 40 CFR Part 98 reporter, including Subpart W petroleum and natural gas systems filers. Separately, EPA is still weighing a pending proposal to suspend Subpart W reporting for most oil and gas segments through RY2034, except natural gas distribution. For compliance managers at covered operators, the extension means extra months to file, but no defensible path to assuming the reporting obligation will vanish. The October 30 filing date covers RY2025 emissions data across every applicable Part 98 subpart, not only petroleum and natural gas systems under Subpart W.

This post is for informational purposes only and does not constitute legal or compliance advice. Consult qualified legal counsel or a compliance professional for guidance specific to your operations and jurisdiction.

What Changed in the GHGRP Deadline?

EPA’s interim final rule, effective now, moves the 2026 GHGRP annual reporting deadline from March 31 to October 30, 2026, for reporting year 2025 data. It applies to every reporter subject to 40 CFR Part 98. Part 98 covers any facility emitting 25,000 metric tons CO2e or more and any supplier or operator otherwise required to report under a specific subpart. Subpart W petroleum and natural gas systems filers are among the covered reporters.

EPA stated that the extension is intended to give the agency additional time to complete related rulemaking activity, including the pending Subpart W reconsideration. Operators subject to Part 98 must still collect the required data and maintain Subpart W records per the existing rule. Calculation methodologies and equipment categories were not modified. Only the filing date moved.

For operators that had already begun assembling their RY2025 Subpart W data package, the work is not wasted. Operators that had not yet started have more calendar time, and also more complexity, because EPA’s reconsideration decision will arrive mid-year.

What Is the Status of the Subpart W Reconsideration?

Separate from the deadline extension, EPA is reconsidering whether to suspend mandatory Subpart W reporting for reporting years 2025 through 2034. The proposal would apply to all Subpart W industry segments except natural gas distribution, which would continue to report on the existing schedule. EPA received more than 53,000 public comments on the reconsideration.

EPA is managing this rulemaking under docket EPA-HQ-OAR-2025-0186 (Reconsideration of the Greenhouse Gas Reporting Program). The docket number is simply EPA’s file identifier for the proposal; the full docket on regulations.gov is where the September 2025 proposed rule, EPA’s supporting fact sheet, and every public comment are posted, and it is the authoritative place to track the proposal and any final action. The proposed rule itself appears in the Federal Register.

If finalized as proposed, the affected segments would not submit annual facility-level Subpart W data during the suspension window. Those segments include onshore production, gathering and boosting, processing, transmission, storage, and LNG-related operations.

The reconsideration is a proposed rule, not a final rule. Until EPA issues a final action, the full Subpart W reporting obligation under 40 CFR Part 98 remains in force for all covered segments. What that obligation still includes is laid out in GHGRP Subpart W reporting in 2026. Final action is expected around mid-2026, with July 2026 referenced in agency schedules. The outcome is not predictable.

EPA has several options. The agency can finalize the suspension as proposed, finalize with modifications, or decline to finalize entirely. A ten-year Subpart W gap would eliminate the main federal facility-level O&G emissions dataset. Analysts and state regulators currently use that dataset to benchmark operator reports against a common template. That loss matters most for data continuity and third-party benchmarking.

For a detailed breakdown of the proposal’s scope and segment-level implications, see EPA Proposes Freezing GHGRP Subpart W O&G Reporting Until 2034: Analyzing What That Means.

Operators subject to both federal and state programs should note that state mandatory reporting is unaffected by any federal reconsideration. Colorado’s ONGAEIR deadline, for example, still falls on June 30, 2026, for RY2025 data, regardless of what EPA does with Subpart W. For a full preparation timeline on the ONGAEIR filing cycle, see the Colorado ONGAEIR June 30 filing checklist.

How Should Operators Use the Extra Seven Months?

The extension is an opportunity to raise the quality of the RY2025 submission, not a reason to pause data work. Seven extra months is real data-quality leverage. Three actions give operators the most leverage with the additional calendar time.

First, close data quality gaps that normally get papered over under March 31 pressure. Equipment inventory drift and missed pneumatic controller reclassifications are common submission issues that benefit from a longer review window. Storage tank data completeness is another category that tends to improve with extra review time. A cleaner submission is easier to defend if the reconsideration is not finalized and RY2025 data is published on schedule.

Second, plan for two possible 2027 reporting postures in parallel. Either full Subpart W reporting resumes on schedule, or the suspension is finalized and reporting does not occur until RY2035. Treating Subpart W as the sole driver of emissions data collection exposes a company if federal rules tighten again after 2034.

Operators with Colorado ONGAEIR obligations or OGMP 2.0 commitments will need to continue measurement and inventory work. Supply-chain methane intensity requirements also remain in force even if federal reporting is suspended.

Third, reconcile internal inventory methodology with published Subpart W calculation methods while the submission is still in draft. Alvarez et al. (2018, Science) found that factor-based inventories undercount actual facility methane emissions by roughly a factor of two. Operators that can document their methodology cleanly are better positioned regardless of outcome.

Frequently Asked Questions

Does the October 30, 2026 deadline apply to all GHGRP subparts or only Subpart W?

The interim final rule extends the RY2025 deadline for all reporters covered by 40 CFR Part 98, not only Subpart W. The extension applies to every applicable subpart for the RY2025 submission cycle. Facilities that report under Subpart C, Subpart W, or any other applicable subpart have until October 30, 2026 to submit. Calculation, monitoring, and recordkeeping requirements for each subpart were not modified by the interim final rule.

Do operators need to keep collecting Subpart W data while the reconsideration is pending?

A proposed rule does not displace an existing final rule, so 40 CFR Part 98 remains fully in force until EPA issues a final action. Operators must continue Subpart W monitoring and recordkeeping per the existing rule. Stopping data collection on the assumption that the reconsideration will be finalized is not a defensible compliance posture.

When will EPA decide on the Subpart W reconsideration?

EPA has indicated a target of mid-2026 for final action, with July 2026 referenced in agency schedules. The final outcome is not yet known, and the schedule could shift based on comment review or litigation. EPA received more than 53,000 comments, which on its own can extend the review timeline.

If Subpart W reporting is suspended, do state mandatory programs go away?

State programs are independent of GHGRP and continue on their own statutory and regulatory schedules. Colorado’s ONGAEIR, for instance, continues on its June 30 filing cycle for each reporting year. OGMP 2.0 and the EU Methane Regulation also operate outside of GHGRP. Supply-chain methane intensity requirements follow the same pattern.

What should data analysts plan for if Subpart W is suspended?

Analysts who rely on Subpart W for facility-level O&G emissions should begin building alternative data sources now. State programs like Colorado’s ONGAEIR publish facility-level data and can partially substitute for Subpart W in states with mandatory programs. The TetraSoft Atlas Dashboard, a subscription platform, aggregates state-reported facility and production data for Colorado and Texas and is one such alternative.

Never miss an ONGAEIR or GHGRP deadline. Subscribe for compliance updates and regulatory news.

References