Subpart W Proposed Rule: Is GHGRP Reporting Still Required?

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 between February 2025 and April 2026 created the confusion: a proposed Subpart W suspension, the disapproved IRA charge rule, and uncertain OOOOb/OOOOc status, unpacked in EPA OOOOb/c status is uncertain [4] [7]. [8] None of those actions, including the proposed suspension, removed or suspended the core Subpart W reporting obligation for covered facilities [2].

For compliance professionals, the operational question is narrow: what must you still file, and what deadline changed? This guide covers the proposed rule’s status, the RY2025 deadline, a five-step compliance table, and how Subpart W differs from the IRA charge and OOOOb/OOOOc.

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 [2]. EPA proposed suspending Subpart W reporting obligations for reporting years 2025 through 2034 on September 16, 2025 (90 FR 44591) [4]. That proposal is under review [2]. Until EPA publishes a final rule in the Federal Register, the existing Subpart W requirements apply without modification [1].

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) [6]. 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 [4]. 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 [5].

How to Comply With Subpart W for RY2025 Before March 10, 2027

Compliance for reporting year 2025 comes down to five steps, each set by a section of 40 CFR Part 98 [10] [11]. [12] Read the table as a working Subpart W guide for this filing cycle.

Step	What to do	Rule	When
1. Confirm you must report	Test each industry segment’s listed emission sources against the 25,000 metric tons CO2e threshold	40 CFR 98.2(a)(2), 98.231	Before calculating
2. Confirm your designated representative	Each facility has one designated representative, named in a certificate of representation, who certifies and submits the report	40 CFR 98.4(a), 98.4(i)	Before submitting
3. Calculate emissions by source type	Apply the Subpart W calculation methods to each source type in each segment	40 CFR 98.233	For the full reporting year
4. Keep the records	Keep the GHG Monitoring Plan, measurement dates and results, calibration reports, calculation inputs and outputs, and each missing-data substitution	40 CFR 98.3(g), 98.237	At least 3 years after submission
5. Submit, then correct	Submit the RY2025 report, and file a revised report within 45 days of finding a substantive error	40 CFR 98.3(b)(6), 98.3(h)(1)	By March 10, 2027

The deadline in step 5 is in the regulation itself. As revised on October 14, 2026, 40 CFR 98.3(b)(6) reads: “The annual GHG report for reporting year 2025 must be submitted no later than March 10, 2027.” [10] [16] That revision is an interim final rule that changes only the deadline; it does not finalize the proposed suspension [16].

What Changed for Subpart W Reporting in 2025 and 2026?

EPA extended the RY2025 reporting deadline to October 30, 2026 (final rule), then to March 10, 2027 (interim final rule), and separately proposed suspending Subpart W reporting for RY2025 through RY2034 (not finalized).

None of the federal actions since March 2025 removed the RY2025 Subpart W filing; the report is now due 10 March 2027. [10] [13] [16]

The RY2025 Deadline Moved to October 30, 2026, Then to March 10, 2027

EPA published a 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 [3]. The mechanics of that extension are covered in GHGRP Subpart W Deadline Moved to March 10, 2027. This is a final rule, not a proposal. On October 14, 2026, EPA moved the deadline again, to March 10, 2027, in an interim final rule (91 FR 65112) [16]. The extended deadline applies to all GHGRP source categories, not only Subpart W.

The extensions give facilities additional time to compile and submit RY2025 data through EPA’s e-GGRT system. They do not eliminate the reporting obligation. Facilities that would otherwise have been required to report by March 31, 2026 are now required to report by March 10, 2027 [16].

The Proposed Suspension Covers RY2025 Through RY2034

EPA’s September 2025 proposal (90 FR 44591) would remove the natural gas distribution segment after RY2024 and suspend the other nine segments through RY2034 [4]. Those nine are onshore production, offshore production, gathering and boosting, processing, transmission compression, transmission pipelines, underground storage, LNG storage, and LNG import and export [1]. The proposal has not been finalized [2]. EPA’s own GHGRP rulemaking notices page lists the September 2025 action as a proposed rule.

If EPA finalizes the suspension before March 10, 2027, 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 March 10, 2027. EPA stated in the 91 FR 9712 preamble that it anticipated finalizing the substantive reconsideration rule by July 2026. That date passed without a final rule [13]. EPA then extended the deadline to allow “additional time to consider comments on the GHGRP Reconsideration Proposal and to take any final action on that proposal,” so compliance teams should plan to file by March 10, 2027 [16].

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 Deferred to 2034

Congress disapproved EPA’s implementing rule for the IRA Methane Waste Emissions Charge (authorized under IRA Section 60113) under the Congressional Review Act, in a resolution signed March 14, 2025 [7]. The July 2025 budget law then moved the charge’s start to calendar year 2034 [14]. The underlying 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 is a per-ton charge on reported methane emissions above 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 amended its 2024 OOOOb and OOOOc methane standards for new and existing oil and gas sources on April 9, 2026 (91 FR 18056, April 9, 2026) [15]. The narrow final rule changed two provisions: temporary flaring of associated gas and net heating value monitoring for flares and enclosed combustion devices [15]. 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 (for example, leak detection and 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. For what the standard covers and who it applies to in the first place, see EPA OOOOb Explained: Who It Covers and What It Requires.

Frequently Asked Questions

Which GHGRP Source Categories Are Affected by the Deadline Extension?

The RY2025 deadline extension, now to March 10, 2027, applies to all GHGRP source categories, not only Subpart W. Subpart C, Subpart NN, and other applicable subparts also received the extension. Operators with reporting obligations across multiple subparts should use the same March 10, 2027 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 March 10, 2027?

If EPA publishes a final rule suspending Subpart W reporting before March 10, 2027, the RY2025 reporting obligation would likely be removed. The specific terms would depend on the final rule’s language and effective date. EPA’s 91 FR 9712 preamble anticipated a final reconsideration rule by July 2026. That date passed without one, and EPA instead moved the RY2025 deadline to March 10, 2027. 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. 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. Public Law 119-2 (H.J. Res. 35). Congressional Review Act disapproval of EPA’s rule “Waste Emissions Charge for Petroleum and Natural Gas Systems” (89 FR 91094). Passed the House February 26 and the Senate February 27, 2025; approved March 14, 2025. https://www.govinfo.gov/content/pkg/PLAW-119publ2/html/PLAW-119publ2.htm
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/flight/
10. 40 CFR 98.3. General monitoring, reporting, recordkeeping, and verification requirements, including the RY2025 deadline at paragraph (b)(6), recordkeeping at (g), and revisions at (h). US Code of Federal Regulations. https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-98/subpart-A/section-98.3
11. 40 CFR 98.4. Authorization and responsibilities of the designated representative. US Code of Federal Regulations. https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-98/subpart-A/section-98.4
12. 40 CFR 98.231, 98.233, and 98.237. Subpart W reporting threshold, calculation methods, and records that must be retained. US Code of Federal Regulations. https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-98/subpart-W
13. Federal Register, Docket EPA-HQ-OAR-2025-0186. Documents published through September 22, 2026: 90 FR 44591 (proposed, September 16, 2025), 90 FR 45367 (correction), 91 FR 9712 (final, February 27, 2026), and 91 FR 34161 (correction, June 5, 2026). https://www.federalregister.gov/documents/search?conditions%5Bdocket_id%5D=EPA-HQ-OAR-2025-0186
14. Public Law 119-21, Section 60012(b). Amends Clean Air Act Section 136(g) by replacing “calendar year 2024” with “calendar year 2034”. Approved July 4, 2025. https://www.govinfo.gov/content/pkg/PLAW-119publ21/html/PLAW-119publ21.htm
15. 91 FR 18056, April 9, 2026. Reconsideration of Standards of Performance for New, Reconstructed, and Modified Sources and Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review. Final rule. Docket EPA-HQ-OAR-2024-0358. https://www.federalregister.gov/documents/2026/04/09/2026-06808/reconsideration-of-standards-of-performance-for-new-reconstructed-and-modified-sources-and-emissions
16. 91 FR 65112. Extending the Reporting Deadline Under the Greenhouse Gas Reporting Rule for Reporting Year 2025 to March 10, 2027. Interim Final Rule. October 14, 2026. US Environmental Protection Agency. https://www.federalregister.gov/documents/2026/10/14/2026-20982/extending-the-reporting-deadline-under-the-greenhouse-gas-reporting-rule-for-reporting-year-2025-to