EPA Extends 2025 GHG Deadline as State Rules Expand

By Elena Vasquez

More than 8,000 U.S. facilities now face a March 10, 2027 deadline to report their 2025 greenhouse gas emissions, after EPA moved the date from Oct. 30, 2026, leaving the federal program intact but unsettled.

For compliance teams, the new federal calendar compresses two filing dates into a 21-day window: March 10 and March 31, 2027, even as California, Washington, New York and Colorado revise or enforce separate reporting regimes.

What did EPA change?

EPA’s Oct. 14, 2026 interim final rule issued the second extension of the 2025 GHGRP deadline. EPA previously moved it from March 31 to Oct. 30, 2026, then delayed it again while the agency considers its September 2025 proposal to eliminate reporting for nearly all program source categories.

For this extension, EPA invoked the Administrative Procedure Act’s “good cause” exception, allowing the agency to postpone the deadline without advance notice or an opportunity for public comment. The administration has repeatedly used that exception to postpone other regulatory deadlines while pursuing deregulation.

EPA cited two reasons for the latest delay:

• More than 50,000 comments on its proposed GHGRP repeal required additional review time.
• EPA could not prepare its electronic Greenhouse Gas Reporting Tool, known as e-GGRT, for the former October deadline.

The September proposal would preserve reporting for certain petroleum and natural gas industry segments covered by Subpart W, but suspend their obligations until 2034. The comment period closed in November 2025.

EPA Administrator Zeldin reportedly indicated in October 2026 that the agency “had not yet settled on the preliminary scope of a final rule.” That suggests final action could remain months away.

On Oct. 22, Environmental Defense Fund and Environmental Integrity Project challenged the latest extension in the U.S. Court of Appeals for the D.C. Circuit.

The overlap between the two federal deadlines could push EPA toward a decision on the broader proposal. If the agency issues another extension, it would likely need to move both reporting years.

What could happen to the federal program?

EPA has undergone a major reorganization since January 2025, including an overhaul of the office that administers GHGRP. The agency also has lost nearly one-quarter of its workforce, which may constrain its rulemaking capacity and affect priorities for the rescission proposal.

Industry submitted comments asking EPA to retain the GHGRP in whole or in part. Congress also pressed the agency to withdraw the proposal. Republican Senator Kevin Cramer of North Dakota and Democratic Senator Sheldon Whitehouse of Rhode Island cited potential effects on carbon-capture investments and the competitiveness of U.S. energy exports.

EPA has largely rolled back other greenhouse gas authorities covering mobile and stationary sources, but the agency has not settled on how to proceed with the GHGRP. The outcome could disappoint stakeholders on either side.

Litigation over EPA’s broader Clean Air Act deregulatory agenda may also affect the reporting decision. Challenges already target EPA’s position that it lacks authority to regulate vehicle greenhouse gas emissions, and further challenges to proposed rollbacks are expected.

A final GHGRP rescission would likely face its own litigation, including arguments that collecting certain emissions data does not serve a statutory purpose. A future administration could also seek to restore the program or a modified version. That litigation could extend beyond the current administration’s tenure, extending uncertainty for reporting entities.

Which state reporting rules changed?

• California’s Mandatory Reporting Regulation: On Aug. 31, 2026, the California Office of Administrative Law approved amendments to the California Air Resources Board’s Mandatory Reporting Regulation. The changes took effect Sept. 1 and support implementation of the state’s Cap-and-Trade Program.

• California corporate reporting: On Oct. 12, state officials approved CARB’s initial regulation implementing SB 253 and providing basic requirements under SB 261. Detailed SB 261 requirements remain on hold because a court enjoined that law pending appeal in Chamber of Commerce v. Sanchez, which challenges both statutes.

• California deadlines: Under SB 253, covered companies must submit their first Scope 1 and Scope 2 emissions reports by Nov. 10, 2026, then publish their disclosures within 90 days of that deadline. CARB clarified that companies must assess applicability individually. Its rulemaking for reporting in 2027 and beyond remains underway.

• Washington: On Sept. 17, the Department of Ecology adopted amendments to the Reporting of Emissions of Greenhouse Gases rule, WAC 173-441, and the Climate Commitment Act Program Rule, WAC 173-446. Effective Oct. 24, the changes require electric power entities to report anything above zero emissions, replacing the previous 10,000 metric tons of CO2-equivalent threshold for 2027 emissions.

New York enforcement: The Department of Environmental Conservation said it will not enforce the June 1, 2027 deadline for reporting 2026 emissions until Dec. 31, 2027. NYSDEC plans to amend 6 NYCRR Part 253 following May 2026 changes to the Climate Leadership and Community Protection Act. The letter delays enforcement but leaves the rule’s substantive requirements intact.

New York litigation: A federal court dismissed Iowa v. James, No. 4:26-cv-00752, in August 2026 for lack of personal jurisdiction. Later that month, American Fuel & Petrochemical Manufacturers filed American Fuel & Petrochemical Manufacturers v. James, No. 1:26-cv-07203, in the Southern District of New York, arguing that the Clean Air Act preempts the reporting program. An October stipulation paused the case until April 2027, limited certain out-of-state reporting requirements and preserved the extended enforcement deadlines.

Colorado: The state developed its own workbooks and reporting form rather than push its existing Oct. 2 filing deadline. Colorado historically used e-GGRT, but EPA acknowledged in its October rule that the tool cannot accept 2025 emissions data. Continued state adoption of separate systems could produce different reporting methods over time.

What should operators do now?

EPA will accept comments on the latest extension until Nov. 30, 2026. Regulated entities should continue collecting 2025 and 2026 emissions data ahead of the March deadlines unless EPA takes further action. Multi-state operators also need to assess state deadlines, thresholds and calculation methods separately from federal obligations, while international operations face growing mandatory reporting requirements elsewhere.

EPA’s Nov. 30 comment close is the next fixed marker. A final decision on the proposed repeal, together with any court challenge, will determine whether the March 2027 federal filings stand.