EPA GHG reporting 2026: the October 30 deadline, Part 98 requirements, thresholds and reporting software

Last updated August 2026. Covered facilities must still submit their reporting year 2025 greenhouse gas report to EPA through e-GGRT by October 30, 2026. That date is not guidance, it is regulation text: EPA amended 40 CFR 98.3(b)(6) in a final rule published at 91 FR 9712 on February 27, 2026, moving the deadline from March 31, 2026. The separate proposal to rescind most of the program, published September 16, 2025 at 90 FR 44591, has not been finalized. EPA said in February 2026 that it anticipated finalizing by July 2026. That month passed with no final rule.

This page sets out who is covered, what the thresholds actually say, what you file, and where the federal program ends and your other emissions obligations begin. Being clear about that boundary matters commercially, because the obligations most likely to outlive the federal rule run on the same fuel and utility records, and that is where our carbon accounting software works.

No. EPA proposed to eliminate most of it and has not finalized that proposal. The Greenhouse Gas Reporting Program remains binding law today, and reporting year 2025 reports are due October 30, 2026. Facilities skipping that deadline are relying on a rule that does not exist yet.

The confusion is understandable, because three different things happened close together and coverage blurred them. Keeping them apart is the whole of the answer.

One correction worth making explicitly, because it circulates in the opposite direction too. The September 2025 proposal does not preserve reporting for fuel and industrial gas suppliers. The supplier subparts LL, MM, NN, OO and PP are on the removal list. The only category kept is Subpart W, petroleum and natural gas systems, and even there the natural gas distribution segment would be removed permanently while the other nine segments would be suspended until reporting year 2034. If that proposal is finalized as written, close to nobody files an annual report. It has not been finalized.

October 30, 2026 for reporting year 2025 emissions. The extension applies only to that year. Reporting year 2026 reverts to the standing rule at 40 CFR 98.3(b), which requires submission by March 31 of the following calendar year, so March 31, 2027 unless EPA acts again.

The two-year pattern of late extensions is why some compliance teams now wait to see whether another one arrives. That is a defensible read of EPA behavior and a poor basis for a control document. A June 5, 2026 correction at 91 FR 34161 touched the February rule, and EPA stated it was typographical with no substantive effect, so nothing there moved the October date. Commentators have noted a further postponement rule under RIN 2060-AX03 appearing on the Unified Agenda, but nothing has been published. Until something is, October 30 is the operative date and no enforcement discretion or no-action assurance is on the record for it.

More than 8,000 direct emitters and suppliers, by EPA's own count. Coverage is decided by 40 CFR 98.2(a), which sets out four separate routes in. You are covered if any one of them applies, and the most common mistake is checking only the famous 25,000 ton threshold when your category never had a threshold at all.

Two details decide a surprising number of borderline cases. The first is that route (a)(1) has no threshold: a small cement or lime plant reports regardless of how little it emits. The second is that the 25,000 ton test in route (a)(2) is a combined figure across combustion and every applicable listed category, not a per-unit or per-category test, so a site that fails each category individually can still clear the threshold in aggregate. Research and development activities are excluded under 98.2(a)(5).

Note also what the threshold is not. GHGRP coverage is a facility-level federal filing test. It says nothing about whether you owe a corporate greenhouse gas inventory to California, to a customer or to an investor, and those obligations have their own, usually much lower, triggers.

You report direct emissions from your own facility, by source category, using the calculation methods prescribed in the subpart that applies to you, and you submit through EPA's electronic system rather than by document. There are 52 subpart designations from A through ZZ, four of them reserved (B, J, M and KK), and subpart A carries the general provisions, which leaves 47 source categories. Five of those, VV, WW, XX, YY and ZZ, became effective for reporting year 2025.

Table A-1 uses IPCC AR5 100-year global warming potentials, with AR6 values filling gaps for gases that lack a chemical-specific AR5 figure. Methane is 28, nitrous oxide is 265, sulfur hexafluoride is 23,500 and carbon dioxide is 1. Those values arrived in the final rule at 89 FR 31894, published April 25, 2024 and effective January 1, 2025, so reporting year 2024 reports were the first to use them.

This table is the single most useful thing on the page for anyone running both a federal filing and a corporate inventory, because the two want different numbers for the same physical emissions. EPA Part 98 is AR5. CDP expects AR6. A team that computes methane once at 28 and reuses it in a questionnaire that assumes 29.8 has introduced a silent inconsistency that an assurance provider will find and that nobody will be able to explain a year later. Pick a GWP set per deliverable, record which one produced each figure, and never let a number cross between the two without being restated. The wider explanation is in what CO2e and GWP actually mean.

No, and treating them as the same is the most expensive mistake in this area. GHGRP is a facility-level federal filing of direct emissions, using EPA-prescribed methods, for the sites that meet a threshold. A corporate greenhouse gas inventory is an organization-level accounting of Scope 1, Scope 2 and Scope 3 under the GHG Protocol, across a boundary you define, for disclosure to regulators, customers and investors.

The overlap is real but partial. Your Subpart C stationary combustion data and your Scope 1 fuel data come from the same invoices and the same meters, so a company that has collected one has done much of the groundwork for the other. What does not carry across is everything above the combustion line: purchased electricity, the boundary decision, and the entire value chain. That is why a facility with a complete GHGRP filing history can still be starting from nothing when a customer asks for a company footprint.

Your federal filing goes away. Most of the rest of your emissions reporting does not, and in several cases it is expanding to fill the gap. This is the part worth planning around, because it is the part that decides whether the data work you are doing now has any residual value.

Read that table and the planning conclusion is fairly blunt. The federal filing is the obligation most likely to disappear, and it is also the one that does the least for you commercially, because nobody buys from you on the strength of an e-GGRT submission. The obligations that persist are the ones a customer, an investor or California asks about, and every one of them wants an organization-level GHG Protocol inventory rather than a facility filing. If you are deciding where to put effort in the next twelve months, put it in the inventory. California specifically is covered on California climate disclosure software and SB 253 reporting software.

Here we should be straightforward about what this product is and is not. A GHGRP submission is made through e-GGRT, EPA's own free electronic system, and the calculation methods are prescribed subpart by subpart. Tools that specialize in Part 98 exist and are built around those prescribed tiers, monitoring data and the certification workflow. Carbonaccounting.ai is not an e-GGRT filing tool and does not compute Subpart W or Subpart C tier calculations. If your only requirement is the federal filing, buy something built for it, or use e-GGRT directly.

Where a carbon accounting platform earns its place is the other half of the picture: the corporate Scope 1, 2 and 3 inventory that California, CDP, your customers and your investors want, built from the accounts payable, utility and fuel records you already keep. Those are the same source documents your combustion data comes from, which is why the two jobs are usually done by the same person and why keeping them in one evidence trail is worth something. What that looks like in practice is on GHG accounting software, and the vendor landscape is compared honestly on best carbon accounting software.

If the federal question is settled and the corporate inventory is what remains, start with GHG accounting software for the method and how to calculate Scope 3 emissions for the hard part. If a customer request rather than a regulator is what brought you here, supplier emissions reporting software is written for that position and the CDP questionnaire covers the most common form it takes. For the California obligations that are now the binding US floor, see SB 253 reporting software. Costs across all of it are on carbon accounting software cost.