EPA Proposes Overhaul of Greenhouse Gas Reporting Program

On September 16, 2025, the U.S. Environmental Protection Agency (EPA) published a proposed rule that would fundamentally reshape the federal Greenhouse Gas Reporting Program (GHGRP). 90 Fed. Reg. 44591 (Sept. 16, 2025). If finalized, this action would mark a further shift in federal greenhouse gas (GHG) policy and advance the administration’s broader deregulatory agenda.

Background

EPA’s proposal would eliminate federal reporting obligations for a wide range of industrial sectors and suspend most remaining requirements until 2034. EPA issued the GHGRP under the Clean Air Act (CAA), in response to a mandate by Congress in the Consolidated Appropriations Act of 2008. The law requires certain large suppliers of fossil fuel and direct sources of GHG emissions to monitor and report their annual GHG emissions to EPA. EPA’s current proposed rule] responds to President Trump’s Executive Orders 14154 (Unleashing American Energy) and 14192 (Unleashing Prosperity Through Deregulation) — and is one of dozens of regulatory changes EPA Administrator Lee Zeldin announced in March 2025.

Key Proposed Changes 

EPA is proposing two fundamental changes to the GHGRP as follows.   

Permanently remove GHG reporting obligations for most source categories.  The proposed rule would permanently remove reporting obligations for 46 source categories across the U.S. economy. This includes stationary fuel combustion, electricity generation, aluminum and cement production, petroleum refining, pulp and paper manufacturing, municipal solid waste landfills, wastewater treatment, and suppliers of fuels and industrial GHGs. It would also eliminate requirements for suppliers of carbon dioxide, geologic sequestration, and carbon injection activities. Together, these removals would effectively terminate federal GHG reporting for most industries after reporting year 2024.

Defer reporting for the oil and natural gas sectors.  For the petroleum and natural gas industry, EPA proposes to defer reporting for nine oil and natural gas segments — including onshore and offshore production, natural gas processing, transmission compression, pipelines, underground storage, and liquefied natural gas storage, import, and export facilities — until 2034.  This would align the reporting rules with the current timeline for the Waste Emissions Charge (WEC) established in the Inflation Reduction Act.  Congress imposed the WEC on segments of the oil and natural gas source category found in subpart W of EPA’s GHGRP regulations and based the fee on methane emissions data to be collected under the GHGRP. The WEC had been due to begin in 2025, but the One Big Beautiful Bill Act (OBBBA) delayed implementation of the WEC until 2034.

EPA’s Rationale 

EPA justifies its proposal on several grounds.

First, EPA asserts that Section 114 of the CAA does not provide sufficient authority to mandate ongoing GHG reporting for most categories, as the data are not needed to implement other provisions of that Act.

Second, CAA Section 136, which governs the Methane Emissions Reduction Program — including the WEC — requires reporting only for certain segments of oil and natural gas systems, and only beginning with reporting year 2034, based on Congress’s amendment of the requirements in the OBBBA.

Finally, EPA emphasizes that the deregulatory direction provided by recent executive orders and the statutory amendments enacted in July 2025 compel a reassessment of the GHGRP’s costs and benefits. In light of these factors, EPA has concluded that continuous, economy-wide GHG reporting is unnecessary and imposes an undue burden on industry.

Business Impacts and Next Steps

The proposal has broad implications for reducing reporting entities’ costs while also reducing the availability of data that other entities use in transactions.

Cost savings for reporting entities.  For regulated entities, the proposal offers immediate relief from federal reporting obligations and marks one of the most significant EPA deregulatory actions of this administration to date. Facilities that have historically reported under the GHGRP would not need to submit data for 2025 and would not be expected to maintain records or submit amended reports for subsequent years. EPA estimates that its proposal would generate cost savings of approximately $303 million annually between 2025 and 2033, with total savings of $2.0 to $2.4 billion over a 10-year period, depending on the discount rate applied. The oil and natural gas sector accounts for most of these savings, and the reductions reflect the elimination of both direct reporting costs and associated recordkeeping obligations.

The GHGRP data is currently used for multiple purposes.  The proposal does have broader implications, as the data collected and reported through the GHGRP is used for multiple purposes. Numerous state programs rely on GHGRP data for their GHG emissions inventories, which would mean states would have to stand up their own state-run tools. Likewise, various federal programs such as the Section 45Q carbon capture sequestration credit, the Section 45V clean hydrogen credit, and the American Innovation and Manufacturing Act’s phasedown of hydrofluorocarbons all incorporate GHGRP methodologies or data sets, so changes to those programs may be required. For example, without the GHGRP data, the Treasury Department might need to provide new guidance to ensure project developers can continue to secure tax credits for new and existing projects. Likewise, other internal data collection systems or voluntary reporting frameworks may need to fill in where documenting GHG emissions might be required.

EPA will accept public comments until November 3, 2025, with a virtual public hearing scheduled for October 1. More details are available here. Companies should closely evaluate how the proposed changes would affect their reporting burdens, compliance obligations, and broader corporate reporting strategies.

This post is as of the posting date stated above. Sidley Austin LLP assumes no duty to update this post or post about any subsequent developments having a bearing on this post.