EPA GHGRP Reporting Guide for Oil & Gas | Validere

EPA’s Greenhouse Gas Reporting Program requires covered oil and gas facilities and suppliers to do more than report an annual emissions total. Depending on the applicable 40 CFR Part 98 requirements, teams may need to collect operational and measurement data, apply prescribed calculation methods, complete QA/QC, retain supporting records, submit through e-GGRT, and respond to EPA verification questions.

This guide orients environmental and emissions professionals across upstream, midstream, processing, transmission, refining, and related petroleum and natural gas operations. It covers what the GHGRP is, how reporting generally works, which Part 98 subparts are commonly relevant across the oil and gas value chain, and what is current versus proposed as of the last reviewed date below.

EPA defines the requirements. This guide helps environmental teams understand how those requirements translate into the reporting workflow. It is not legal advice, not an applicability determination, and not a substitute for Part 98 or current EPA reporter materials.

GHGRP status in 2026

EPA is reconsidering portions of the GHGRP. In September 2025, EPA proposed major changes to program obligations. Those proposed changes are not current law unless and until EPA finalizes them. Separately, EPA finalized an extension of the Reporting Year (RY) 2025 reporting deadline to October 30, 2026. That action extends the deadline; it does not finalize the broader reconsideration. Current Part 98 requirements remain in effect while the proposal is pending. See EPA’s rulemaking notices for GHG reporting. This article reflects publicly available EPA materials and Part 98 as of August 9, 2026.

What is the EPA Greenhouse Gas Reporting Program (GHGRP)?

The GHGRP is EPA’s mandatory federal program, codified at 40 CFR Part 98, that requires reporting of greenhouse gas (GHG) data and other relevant information from large GHG emission sources, fuel and industrial gas suppliers, and CO2 injection sites in the United States. See What is the GHGRP? and the GHGRP homepage.

In practical terms:

• Reporting requirements are organized into Part 98 subparts by source category or supplier category.
• Covered facilities and suppliers generally submit annual reports for the prior calendar year.
• Direct emitters report at the facility level (with parent company information also collected). Suppliers report at the corporate level for the products they supply.
• Facilities calculate emissions using methodologies specified in Part 98 and submit data through EPA’s electronic Greenhouse Gas Reporting Tool (e-GGRT).

GHGRP is a regulatory reporting program. It is not an emissions limit program, and it is not the same thing as a corporate GHG inventory prepared under the GHG Protocol.

EPA notes that GHGRP facility-level data does not automatically equal all GHG emissions associated with a parent company. Separate boundary and methodology decisions still apply for corporate inventories or voluntary frameworks. For one voluntary methane reporting framework used by some oil and gas companies, see Validere’s OGMP 2.0 guide.

GHGRP status in 2026: what is current and what is proposed?

Has GHGRP reporting been eliminated? As of this article’s last reviewed date, no. EPA has proposed major changes, and EPA has finalized a RY2025 deadline extension. Those are different actions.

EPA’s general description of annual timing remains March 31 for the prior calendar year, subject to specific-year changes such as the RY2025 extension to October 30, 2026. Confirm the current deadline on EPA’s rulemaking notices and e-GGRT notices before filing.

Who reports under the GHGRP?

Applicability under the GHGRP depends on Part 98 and the relevant subpart(s). It is not a single universal test.

EPA’s For GHG Reporters page states that Part 98 applies to certain facilities that emit 25,000 metric tons or more of GHGs per year; certain suppliers of fossil fuels, industrial GHGs, and products containing GHGs; and facilities that inject CO2 underground.

On What is the GHGRP?, EPA explains that facilities and suppliers determine whether they are required to report based on industrial operations, emission levels, or other factors. EPA also states that facilities and suppliers are generally required to submit annual reports under Part 98 if:

• GHG emissions from covered sources exceed 25,000 metric tons CO2e per year;
• supply of certain products would result in over 25,000 metric tons CO2e of GHG emissions if those products were released, combusted, or oxidized; or
• the facility receives 25,000 metric tons or more of CO2 for underground injection.

Some source categories use different criteria. EPA’s oil and gas industry page states that Subpart Y (Petroleum Refineries) does not specify a minimum emissions threshold and applies to facilities that meet the source category definition. Subpart-specific thresholds and facility definitions can also differ within oil and gas, including under Subpart W.

EPA provides an Applicability Tool for facility source categories, along with separate guidance for suppliers, importers, and exporters. EPA states that the Applicability Tool is not intended for suppliers of fossil fuels or industrial GHGs. Reporters should confirm applicability against the governing Part 98 provisions and the relevant subpart materials. EPA also states that each facility must report GHG emissions for all applicable source categories for which calculation methods are provided in the rule.

This guide provides an orientation to the program and does not determine whether a particular facility or supplier is subject to Part 98.

How GHGRP reporting works

Across Part 98, reporting is less about one spreadsheet cell and more about a controlled workflow: determine what applies, gather the right inputs, calculate with the prescribed methods, quality-check the package, submit through e-GGRT, respond to EPA questions if raised, and retain supporting records.

1. Determine applicability and relevant Part 98 subparts. Confirm source or supplier categories, thresholds, facility definitions, and other criteria in the governing subpart text and EPA reporter materials.
2. Identify required sources and data elements. Required emissions sources, activity data, and reporting elements vary by subpart and source type.
3. Collect operational, activity, and measurement information. Inputs may come from production systems, equipment inventories, monitoring results, engineering records, or other operational systems, depending on the applicable methods.
4. Calculate or quantify emissions using applicable Part 98 methodologies. Facilities calculate emissions using methodologies specified in Part 98. EPA notes that reporters generally may choose among allowed methods where the rule provides options, provided they meet the requirements for the method selected.
5. Complete QA/QC and address missing data according to applicable requirements. Subparts include monitoring and quality-assurance provisions and, where applicable, missing-data procedures. Do not assume one subpart’s procedures apply to another.
6. Prepare and submit the annual report through e-GGRT. Annual reports are submitted electronically using EPA’s reporting system.
7. Respond to EPA verification questions or correct submitted information where necessary. After submission, EPA conducts a multi-step verification process. If potential errors are identified, EPA notifies the reporter, who can respond or correct and resubmit.
8. Maintain required supporting records. Retention details are specified in the general provisions and relevant subparts.

Figure 1: GHGRP reporting is a controlled lifecycle from applicability and data collection through calculation, QA/QC, e-GGRT submission, EPA verification, and records.

Applicability → Data → Calculations → QA/QC → e-GGRT submission → EPA verification → Records

The content of each step depends on the applicable subpart. A Subpart W report, a Subpart Y refinery report, and a Subpart MM supplier report are not interchangeable packages.

Which GHGRP subparts are relevant to oil and gas?

Part 98 contains many subparts. Oil and gas organizations may need to evaluate more than one, depending on their activities. EPA’s overview of GHGRP and the oil and gas industry highlights four subparts that commonly appear across the value chain: Subparts W, Y, MM, and NN. Other subparts can also apply at co-located operations (for example, stationary fuel combustion under Subpart C, or other process categories where present).

The table below is an orientation, not an applicability determination.

Subpart W: Petroleum and Natural Gas Systems

Subpart W (40 CFR §§ 98.230–98.238) is the Part 98 source category most often associated with upstream and midstream GHG reporting. EPA states that owners or operators of facilities that contain petroleum and natural gas systems and emit 25,000 metric tons or more of GHGs per year (as CO2e) report GHG data to EPA. Owners or operators collect GHG data, calculate emissions, and follow specified procedures for quality assurance, missing data, recordkeeping, and reporting.

EPA’s Subpart W information sheet lists ten industry segments: onshore petroleum and natural gas production; offshore petroleum and natural gas production; onshore natural gas processing; onshore natural gas transmission compression; onshore petroleum and natural gas gathering and boosting; onshore natural gas transmission pipelines; underground natural gas storage; LNG storage; LNG import and export equipment; and natural gas distribution.

Subpart W is source- and segment-specific. Calculation methods, monitoring and QA/QC requirements, missing-data procedures, and reporting elements are set out in §§ 98.233–98.236 and related provisions. Facility definitions also differ for certain segments, including basin-level definitions for some onshore production and gathering and boosting operations. Those details belong in a dedicated Subpart W guide.

In May 2024, EPA finalized amendments intended to address reporting gaps, expand or improve calculation methodologies so reporting is based more on empirical data, and improve verification and transparency, with implementation phased across RY2024 and RY2025. For current text, use the eCFR Subpart W and EPA’s Subpart W hub.

Subpart Y: Petroleum Refineries

Subpart Y covers petroleum refineries that meet the source category definition. EPA states that Subpart Y does not specify a minimum emissions threshold, so it applies to all petroleum refineries that meet that definition. Refineries may also have obligations under other subparts (for example, combustion under Subpart C, or supplier reporting under Subpart MM).

Subpart MM: Suppliers of Petroleum Products

Subpart MM is supplier-oriented. EPA’s Subpart MM page states that suppliers who must report include refiners (owners and operators of petroleum refineries producing covered petroleum products through distillation of crude oil), and importers and exporters of listed petroleum products or natural gas liquids in quantities equivalent to 25,000 metric tons CO2e or more per year. Under Subpart MM, reporters report information related to the CO2 that would be emitted if supplied products were combusted, released, or oxidized, rather than facility direct process emissions under that subpart.

Subpart NN: Suppliers of Natural Gas and Natural Gas Liquids

Subpart NN applies to natural gas and natural gas liquids suppliers. EPA’s oil and gas overview states that Subpart NN applies to all fractionators of natural gas liquids and to natural gas distribution companies that deliver 460,000 Mscf or more of natural gas per year. Facilities subject to Subpart NN report the emissions that would result from complete combustion or oxidation of the products they sell.

What data goes into a GHGRP reporting workflow?

Required information varies by subpart and emissions source. There is no single universal GHGRP data model.

At a high level, Part 98 reporting workflows may draw on:

• operational and activity data;
• equipment or source information;
• measured parameters;
• production, throughput, or supply data where applicable;
• calculation inputs and factors where the rule allows or requires them;
• monitoring results;
• supporting documentation.

Figure 2: A defensible GHGRP package keeps the connection between source data, the calculation method used, the reported value, and supporting evidence.

The practical challenge is maintaining the connection between each reported value, the underlying source data, the calculation method used, and the supporting evidence.

When that chain breaks, teams can still produce a number. They just cannot efficiently explain how they got there when EPA asks a verification question, an internal reviewer challenges a late change, or next year’s report needs to reuse last year’s methods and inputs.

How EPA verification and record-keeping affect the reporting process

After data are submitted, EPA conducts a multi-step verification process intended to ensure reported data are accurate, complete, and consistent. EPA’s methodology and verification materials state that if potential errors are identified, EPA notifies the reporter, who can resolve the issue by providing an acceptable response explaining why the flagged issue is not an error, or by correcting the issue and resubmitting the annual GHG report. EPA’s verification fact sheet also describes pre-submittal electronic checks and post-submittal review.

Reported GHGRP data are generally made publicly available unless they qualify for confidential treatment under the Clean Air Act.

Record-keeping is part of the same workflow. For Subpart W, EPA’s information sheet states that reporters must retain records pertaining to their annual GHGRP report for at least three years after the date the report is submitted, and points readers to Subpart A and 40 CFR § 98.237.

GHGRP reporting is not only about generating a number by the deadline. Teams also need to understand where values came from, which methodology was used, which inputs supported the calculation, whether data changed after initial preparation, and what evidence supports the submitted report.

Why GHGRP reporting becomes difficult at scale

EPA defines what must be reported. The operating model determines whether a team can produce that report repeatedly without rebuilding the package each year.

A useful way to think about the work is as a chain:

Source data → Calculation → QA/QC → Review → Submission → Evidence

For organizations managing many facilities, sources, or overlapping reporting obligations, that chain can fragment across field systems, operational databases, spreadsheets, environmental software, measurement systems, engineering records, and manual handoffs.

When those stages live in separate systems and teams:

• source data can arrive late or in inconsistent formats;
• calculation methods and versions become hard to reconstruct;
• QA findings may not travel with the reported values;
• late corrections can break the link to prior reviews;
• verification questions require hunting through email, shared drives, and contractor files;
• next year’s cycle starts by rebuilding evidence rather than updating a governed package.

Figure 3: At scale, GHGRP work depends on a connected path from source data through calculation, QA/QC, review, submission, and evidence. Fragmentation in that path is usually the real problem.

These problems become more difficult when reporting spans multiple basins, segments, or subparts, or when the same underlying operations also support other environmental, methane, or corporate disclosure products. The issue is usually not that the team cannot calculate emissions. It is that the workflow around the calculation is fragmented.

How software can support GHGRP reporting

Software can reduce the manual work surrounding GHGRP reporting, but responsibility for determining applicability, using the correct regulatory methodology, and submitting accurate information remains with the reporter.

Capabilities environmental teams often evaluate in emissions reporting software and emissions management software include integrating source data; maintaining calculation logic under version control; preserving traceability from reported values to underlying inputs; supporting QA/QC and exception review; managing supporting evidence; tracking changes; generating reporting-ready outputs for internal review before e-GGRT submission; and supporting audit and management review workflows.

For teams that also automate multi-framework reporting packages, see automating greenhouse gas reporting.

Validere supports regulatory air and GHG reporting workflows by connecting environmental and operational data, emissions calculations, calculation transparency, QA processes, and evidence needed for review.

See how Validere supports regulatory air and GHG reporting.

Frequently asked questions

What is GHG reporting?

GHG reporting is the process of documenting greenhouse gas emissions or related GHG information according to a defined set of rules. In the United States, one major mandatory form is EPA’s Greenhouse Gas Reporting Program under 40 CFR Part 98. Other forms include corporate inventories, voluntary programs, and disclosure regimes. Those products are related but not interchangeable.

What is the EPA GHGRP?

The EPA Greenhouse Gas Reporting Program (GHGRP) is the federal program, codified at 40 CFR Part 98, that requires reporting of GHG data and other relevant information from large GHG emission sources, fuel and industrial gas suppliers, and CO2 injection sites in the United States.

Is GHGRP reporting still required in 2026?

As of August 9, 2026, current Part 98 requirements remain in effect. EPA proposed major changes in September 2025, including proposed elimination or suspension of reporting obligations for many source categories and Subpart W segments. Those changes are proposed only unless finalized. Separately, EPA finalized an extension of the RY2025 reporting deadline to October 30, 2026. Confirm status on EPA’s rulemaking notices.

Who is required to report under the GHGRP?

Applicability depends on Part 98 and the relevant subpart(s). EPA describes general categories that include certain facilities at or above stated emissions levels, certain suppliers, and facilities that inject CO2 underground, but some source categories use different criteria. EPA’s Applicability Tool is designed for facility source categories and is not intended for suppliers of fossil fuels or industrial GHGs; suppliers should use EPA’s separate supplier guidance and the governing Part 98 provisions. This article does not determine applicability for any specific facility or supplier.

What is EPA Subpart W?

Subpart W is the Petroleum and Natural Gas Systems source category of the GHGRP (40 CFR §§ 98.230–98.238). It covers emission sources in ten petroleum and natural gas industry segments and includes source- and segment-specific calculation, monitoring, QA, missing-data, reporting, and recordkeeping provisions.

Is GHGRP the same as the GHG Protocol?

No. GHGRP is a U.S. EPA regulatory reporting program under Part 98. The GHG Protocol is a corporate GHG accounting framework.

How are GHGRP reports submitted?

EPA states that facilities report data using the electronic Greenhouse Gas Reporting Tool (e-GGRT). See EPA’s For GHG Repor ters page and e-GGRT.

Can software automate GHGRP reporting?

Software can automate portions of data collection, calculation management, QA/QC support, documentation, and internal reporting preparation. Applicability determinations, use of the correct regulatory methodology, and responsibility for accurate submission to EPA remain with the reporter.