EPA's second delay pushes 2025 facility emissions reports to March 10, 2027, four months after California's first corporate filings are due on November 10. The federal numbers many inventories lean on may not arrive at all.
Key Takeaways
The federal Greenhouse Gas Reporting Program has long been the quiet backbone of U.S. emissions data. Power plants, refineries, glass and aluminum makers and fuel suppliers file each year, EPA checks the numbers, and companies, states, investors and researchers build on the result. That backbone is now on hold. EPA has pushed the 2025 reports into March 2027 while it decides whether to keep the program at all, and the states have stopped waiting. For a company with a disclosure deadline, the question is no longer what Washington will require. It is which data it can still stand behind without Washington.
The interim final rule, signed by Administrator Lee Zeldin on October 8, moves the reporting year 2025 deadline from October 30, 2026 to March 10, 2027. It is the second move this year. In February, EPA had already pushed the original March 31 deadline to October 30. The program covers industrial facilities that emit at least 25,000 metric tons of carbon dioxide equivalent a year, plus fuel and industrial gas suppliers and carbon injection sites, and roughly 8,200 of them file each year.
EPA gave two reasons. It needs more time to work through more than 50,000 comments on its September 2025 proposal to reconsider the program, which proposed that no industry would have to submit 2025 reports at all. And its electronic reporting tool was not ready. EPA normally opens that system six weeks before a deadline, and the rule concedes there was not time to do so before October 30.
As J.J. Keller notes, the delay applies only to the 2025 report and changes nothing else in the rule. The larger decision is still open. Impakter reports that the underlying proposal would suspend most oil and gas reporting until 2034, drop carbon supply and sequestration reporting, and save an estimated $303 million a year from 2025 to 2033. Comments on the extension close November 30, and petitions for judicial review are due December 14. In Impakter's words, the latest extension "buys time for that decision; it does not settle it."
A Beveridge & Diamond review maps how quickly states have moved to fill the gap. New York finalized its own mandatory reporting rule on December 1, 2025, with first annual reports expected in June 2027 for 2026 emissions. It measures warming over a 20-year horizon rather than the 100 years used by California and federal rules, which makes methane count for more. Iowa and Missouri are challenging it in court. Colorado's Regulation 22 already serves as a state backstop to the federal program, and Oregon and Massachusetts write the federal rules into their own. Washington has proposed widening its power sector reporting.
California is furthest ahead. Under SB 253, companies doing business in the state with more than $1 billion in annual revenue must file Scope 1 and 2 emissions by November 10, 2026. GSI Environmental notes that the federal slowdown is already showing up in the filings: EPA's eGRID 2024 dataset of power sector emission factors has not been released on its usual timeline, so CARB will accept eGRID 2023 or another credible source. Assurance of Scope 1 and 2 figures is expected to become mandatory in 2027, and CARB has proposed requiring five Scope 3 categories that year, including purchased goods and services and business travel.
That proposal is contested in both directions. A September report from Public Citizen and Americans for Financial Reform argues that a partial Scope 3 list would produce incomplete and misleading data, citing CDP figures that Scope 3 averages about 75 percent of a company's total emissions. Whichever way CARB lands, the direction is toward more reporting, not less.
Most large companies never filed to the federal program themselves, so it is tempting to treat the delay as somebody else's problem. It is not. Federal facility data sits underneath emission factors, supplier benchmarks and tax credits. Impakter points to the Section 45Q carbon sequestration credit as one area that relies on it. Beveridge & Diamond notes that businesses asked EPA to keep the program, citing its help with legal requirements imposed by foreign governments and in demonstrating the low carbon intensity of U.S. businesses. Remove it, and a buyer in Europe asking for a supplier's verified plant emissions gets a less certain answer.
The practical risk is a mismatch. A company filing in California in November, preparing assurance for 2027 and answering European customers will be doing it with fewer federal reference points, a patchwork of state methods and suppliers who may read the delay as permission to stop measuring. BSI advises keeping internal greenhouse gas accounting running regardless, and its consultant Desmond Zheng expects "states and cities in the United States to remain diligent in their GHG reporting requirements." The companies that keep collecting will be the ones that can file, and defend, without waiting for EPA.
Guide
CARB's proposed 2027 Scope 3 categories start with purchased goods and services, just as federal facility data thins out. Watershed's guide covers measuring supplier emissions accurately and engaging the suppliers who matter most.
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Webinar
Washington is not the only regulator rewriting reporting rules mid-stream, and European customers still expect supplier data. Sedex experts explain how to keep supply chain reporting on track while the rules shift.
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Report
If suppliers lose their federal reason to measure emissions, the contract has to supply one. This report shows how enterprises use AI for obligation tracking, so data delivery terms are monitored rather than forgotten.
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CARB's first-year guidance lets companies file without assurance, reuse existing data, or submit a letterhead statement. Every filing will be public, and scope 3 and assurance arrive in 2027.
Brussels may push the January 2027 methane import deadline to 2028. The contract language that proves a supplier's emissions data has applied since August 2024, and fines can reach 20 percent of turnover.
