The Greenhouse Gas Reporting Program’s Subpart W, codified at 40 CFR Part 98, remains a mandatory federal reporting obligation for petroleum and natural gas facilities in 2026 [1]. EPA has not finalized any rule suspending or eliminating Subpart W reporting requirements, despite industry speculation to the contrary [2]. Three separate federal actions in twelve months created the confusion: a proposed Subpart W suspension, the IRA charge rescission, and uncertain OOOOb/OOOOc status [3]. The OOOOb/OOOOc uncertainty is unpacked in EPA OOOOb/c status is uncertain. None of those actions removed or suspended the core Subpart W reporting obligation for covered facilities [4]. For compliance professionals, the operational question is narrow: what must you still file, and what deadline changed?

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.

Subpart W Remains in Effect Because EPA Has Not Finalized a Suspension

GHGRP Subpart W reporting is still required: the proposed suspension is not final [5]. EPA proposed suspending Subpart W reporting obligations for reporting years 2025 through 2034 on September 16, 2025 (90 FR 44591) [6]. That proposal is under review [7]. Until EPA publishes a final rule in the Federal Register, the existing Subpart W requirements apply without modification [8].

The GHGRP’s Statutory Authorization Does Not Make Subpart W Permanent

Subpart W is not a permanent statutory mandate. Congress directed EPA to create mandatory GHG reporting through the Consolidated Appropriations Act of 2008 (P.L. 110-161) [9]. EPA’s implementing regulations at 40 CFR Part 98 can be modified through notice-and-comment rulemaking under the Administrative Procedure Act (5 U.S.C. § 553).

The 90 FR 44591 proposal to suspend Subpart W is that kind of rulemaking action [6]. That process is not complete.

EPA has the authority to suspend Subpart W but has not exercised it. Until a final rule publishes, facilities meeting the 25,000 metric tons CO2e threshold must continue to report.

What Changed for Subpart W Reporting in 2025 and 2026?

EPA extended the RY2025 reporting deadline to October 30, 2026 (final rule), and separately proposed suspending Subpart W reporting for RY2025 through RY2034 (not finalized).

The RY2025 Deadline Moved to October 30, 2026

EPA published an interim final rule on February 27, 2026 (91 FR 9712), extending the reporting deadline for reporting year 2025 GHGRP data from March 31, 2026, to October 30, 2026. The mechanics of that extension are covered in GHGRP Subpart W deadline moved to October 2026. This is an interim final rule, not a proposal. The extended deadline applies to all GHGRP source categories, not only Subpart W.

The seven-month extension gives facilities additional time to compile and submit RY2025 data through EPA’s e-GGRT system. The extension does not eliminate the reporting obligation. Facilities that would otherwise have been required to report by March 31 are now required to report by October 30, 2026.

The Proposed Suspension Covers RY2025 Through RY2034

EPA’s September 2025 proposal (90 FR 44591) has two distinct parts [6]. For the natural gas distribution segment, EPA proposed permanent removal from the program after RY2024. For the remaining nine segments of Subpart W, EPA proposed suspending reporting obligations through RY2034. The proposal has not been finalized [7]. EPA’s own GHGRP rulemaking notices page lists the September 2025 action as a proposed rule.

If EPA finalizes the suspension before October 30, 2026, the RY2025 reporting obligation could be removed retroactively. If EPA does not finalize it before that date, covered facilities must submit their RY2025 data by October 30. EPA stated in the 91 FR 9712 preamble that it anticipates finalizing the substantive reconsideration rule by July 2026, though that is a target, not a commitment. Compliance teams risk filing late if they assume that target will be met on schedule.

The ten-year scope of the proposed suspension stands out. For a breakdown of what the proposed suspension would cover, see EPA Proposes Freezing GHGRP Subpart W O&G Reporting Until 2034: Analyzing What That Means.

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Subpart W Is Not the IRA Charge and Not OOOOb/OOOOc

Subpart W, the IRA Methane Waste Emissions Charge, and OOOOb/OOOOc are three separate federal programs with different legal authorities. They do not depend on each other. Each program has a different current status and different compliance implications.

The IRA Methane Waste Emissions Charge Is Rescinded

Congress disapproved EPA’s implementing rule for the IRA Methane Waste Emissions Charge (authorized under IRA Section 60113) via the Congressional Review Act in February 2025. The underlying IRA statutory provision still exists, but no implementation framework is in effect. The charge cannot currently be assessed or enforced against any facility.

Subpart W, by contrast, is a reporting obligation. Subpart W requires covered facilities to calculate and report GHG emissions. The IRA charge was a financial penalty mechanism tied to reported methane volumes exceeding specified thresholds. The rescission of the charge does not affect the obligation to report under Subpart W.

OOOOb/OOOOc Was Amended in April 2026 and May Face Further Action

EPA’s OOOOb and OOOOc standards (the 2024 methane performance standards for new and existing oil and gas sources) were amended in April 2026 through a narrow final rule that revised two specific provisions: temporary flaring allowances for associated gas at oil wellsites and net heating value monitoring requirements for flares and enclosed combustion devices. The broader OOOOb/OOOOc framework remains in effect as amended but may be subject to further modification or legal challenge.

OOOOb/OOOOc sets performance standards for equipment and operations (leak detection, pneumatic controller requirements, flaring limits). Subpart W sets reporting requirements for GHG emissions calculations and annual data submissions. An operator could be subject to Subpart W reporting while OOOOb/OOOOc performance standards are being further modified or challenged, because the two programs operate independently.

For details on the most recent OOOOb/OOOOc changes, see EPA’s April 2026 OOOOb/OOOOc Amendment: What Changed.

Frequently Asked Questions

Which GHGRP Source Categories Are Affected by the Deadline Extension?

The October 30, 2026 deadline extension applies to all GHGRP source categories, not only Subpart W. Subpart C, Subpart NN, and other applicable subparts also received the seven-month extension. Operators with reporting obligations across multiple subparts should use the same October 30 deadline for all submissions.

Does the Proposed Suspension Affect Historical GHGRP Data Access?

EPA’s proposed suspension (90 FR 44591) targets future reporting obligations, not the availability of already-submitted historical data. GHGRP data for reporting years through RY2024 remains publicly accessible through EPA’s FLIGHT tool and data download portal. EPA is reconsidering Subpart W reporting requirements through 2034, which introduces uncertainty about data availability for future reporting years.

What Happens if EPA Finalizes the Subpart W Suspension Before October 30?

If EPA publishes a final rule suspending Subpart W reporting before October 30, 2026, the RY2025 reporting obligation would likely be removed. The specific terms would depend on the final rule’s language and effective date. EPA stated in the 91 FR 9712 preamble that it anticipates finalizing the substantive reconsideration rule by July 2026. That is a target, not a guarantee. Compliance teams should continue preparing RY2025 data until a final rule publishes, since acting on an unconfirmed timeline introduces avoidable risk.

Do State Reporting Programs Change if Subpart W Is Suspended?

State emissions reporting programs operate independently of federal GHGRP requirements. Colorado’s ONGAEIR program, for example, has its own statutory basis, its own reporting thresholds, and its own June 30 annual deadline. A federal Subpart W suspension would not affect any state reporting obligation. Operators who file both ONGAEIR and Subpart W should track each program’s status separately.

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References

  1. 40 CFR Part 98, Subpart W. Mandatory Greenhouse Gas Reporting: Petroleum and Natural Gas Systems. US Code of Federal Regulations. https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-98/subpart-W
  2. EPA GHGRP Rulemaking Notices. Rulemaking Notices for Greenhouse Gas Reporting. US Environmental Protection Agency. Accessed April 2026. https://www.epa.gov/ghgreporting/rulemaking-notices-ghg-reporting
  3. 91 FR 9712. Extension of Reporting Deadline for Reporting Year 2025 Greenhouse Gas Reporting Program Data. Interim Final Rule. February 27, 2026. US Environmental Protection Agency.
  4. 90 FR 44591. Proposed Reconsideration of GHGRP Reporting Obligations, Including Subpart W Suspension for RY2025 through RY2034. Proposed Rule. September 16, 2025. US Environmental Protection Agency.
  5. 74 FR 56260. Mandatory Reporting of Greenhouse Gases: Final Rule. October 30, 2009. US Environmental Protection Agency.
  6. Consolidated Appropriations Act, 2008. Public Law 110-161. Statutory authorization directing EPA to establish mandatory greenhouse gas reporting.
  7. Congressional Review Act Disapproval, February 2025. Congress disapproved EPA’s implementing rule for the IRA Methane Waste Emissions Charge (IRA Section 60113).
  8. 40 CFR Part 60, Subparts OOOOb and OOOOc. Standards of Performance for Crude Oil and Natural Gas Facilities. US Code of Federal Regulations.
  9. EPA GHGRP Data Publication. Facility Level Information on Greenhouse Gases Tool (FLIGHT). US Environmental Protection Agency. Accessed April 2026. https://ghgdata.epa.gov/ghgp/main.do