An oil and gas producer may already report methane emissions under a US or Canadian program, or under a voluntary program. Those reports may not contain everything an EU importer has to provide under the EU Methane Regulation.
The regulation requires importers to report information about methane measurement, verification, and emissions controls for imported oil and gas. Producers and exporters supply much of that information. Those details may be kept in separate inventories, monitoring programs, and operational records.
Who the EU Methane Regulation covers
Regulation (EU) 2024/1787 establishes requirements to measure, report, and reduce methane emissions in the energy sector, including oil, natural gas, and coal. For oil and gas, that includes operations in the EU and requirements for crude oil and natural gas placed on the European market from other countries.
The duties are split across three roles:
- EU operators run covered oil and gas operations in the Union. They measure and report methane, survey for leaks and repair them, and limit venting and routine flaring.
- EU importers submit information about imported supply. These reports go to the designated national authority, known as the competent authority, in the Member State where the importer is established.
- Non-EU producers do not submit the importer’s report to an EU authority. Importers may need information about those producers’ operations, methane emissions, and monitoring practices in order to meet the importers’ own obligations.
If the exporter and the producer are different companies, the importer identifies both.
What oil and gas importers have to report
Under Article 27, EU importers report information about methane measurement, reporting, and mitigation practices associated with imported oil and natural gas. Article 28 introduces additional monitoring, reporting, and verification requirements that depend on when the relevant supply contract was concluded or renewed.
For crude oil and natural gas, Annex IX is the list of what that annual report has to establish.
|
Information area |
Information required under Annex IX |
|---|---|
|
Producer and origin |
Name and address of the exporter and, if different, the producer. Countries and regions where the oil or gas was produced and through which it was transported. |
|
Methane quantification |
Whether the producer, or the exporter where applicable, carries out source-level and site-level measurement and quantification, and the quantification method used for each type of emission. |
|
Independent verification |
Whether that information has independent third-party verification, and the name of the verifier if there is one. |
|
Emissions reporting |
Whether the emissions reporting follows UNFCCC requirements or OGMP 2.0 standards, and, where available, the latest methane emissions report. |
|
Methane controls |
Whether the producer, or the exporter where applicable, applies regulatory or voluntary measures to control methane, including leak detection and repair surveys and measures that control or restrict venting and flaring, with a description of those measures and, where available, the related reports for the last available calendar year. |
A methane inventory can show which emissions were reported and how they were calculated, and still leave out the independent verification, leak surveys, or venting and flaring records an importer needs. Those records help the importer when they cover the same supply and the same reporting period.
How contract dates affect importer requirements
Article 28’s equivalence requirements depend on when the supply contract was concluded or renewed. For contracts concluded or renewed on or after 4 August 2024, importers must demonstrate that monitoring, reporting, and verification at the producer meet the regulation’s equivalence requirements. For earlier contracts, importers must make reasonable efforts to require that same equivalence at the producer. Those efforts may include seeking a contract amendment, and the importer must report them.
The Commission’s import guidance, updated 22 September 2026, says a renewal, including an automatic renewal, or a substantial change to an existing contract may bring it under the newer requirements. Whether a particular amendment qualifies depends on the changes made. The Commission states that this guidance explains the regulation and is not itself legally binding.
Beyond the contract terms, identifying the original producer can be difficult when natural gas is purchased through a trading hub or blended from several producers. The same guidance says the importer has to arrange for the required information to come through the company it contracts with directly, and that unknown origin does not create a general exemption. Producers can support these requests by documenting the origin of their supply, the relevant reporting period, and the methods used to quantify methane emissions. The guidance does not prescribe a tracing method for a commingled stream.
What operators in the Union have to do
For oil and gas produced outside the Union, these operator requirements are also a reference. Under Article 28, importers can demonstrate that producer-level methane monitoring and reporting meets requirements equivalent to those established for EU operators, alongside independent verification.
EU oil and gas operators quantify methane emissions from individual sources, such as equipment and other emission points. Article 12 starts with a source-level report that uses at least generic emission factors: standard factors taken from inventories or databases and not verified by direct measurement. That report was due by 5 August 2025. Later source-level reports use direct measurement where that is possible. Where direct measurement is not possible, they use specific emission factors based on source-level quantification or sampling.
The regulation also requires site-level measurements on its reporting schedule. Those measurements assess emissions across a larger operating area and give operators a basis for comparison with source-level quantification. If the two differ by a statistically significant amount, operators must investigate and reconcile that difference. Emissions reconciliation in oil and gas explains why those totals can disagree. A verifier assesses the report before it goes to the competent authority.
Operators must also establish and carry out leak detection and repair (LDAR) programs, including the surveys and repairs the regulation requires. The regulation restricts venting and routine flaring, subject to specified exceptions and conditions.
Deadlines in the regulation, and changes still under negotiation
These are the dates in Regulation (EU) 2024/1787 as adopted.
|
Obligation |
Who |
Adopted timing |
|---|---|---|
|
Annual information on imported supply |
Importer |
First report by 5 May 2025, then by 31 May each year |
|
Equivalent monitoring, reporting, and verification |
Importer |
Applies from 1 January 2027 for contracts concluded or renewed on or after 4 August 2024. Earlier contracts: reasonable efforts from the same date |
|
Methane intensity reporting and limits |
Union producers and importers |
Report by 5 August 2028. From 5 August 2030, demonstrate that intensity is below the maximum values the Commission sets |
The date an obligation begins is not necessarily the date the supporting information is submitted. Under the adopted regulation, Article 28 equivalence applies from 1 January 2027. The Commission’s September 2026 guidance reads the report covering calendar year 2027 as due by 31 May 2028.
The 5 August 2028 intensity report applies to contracts concluded or renewed on or after 4 August 2024. The same guidance says that report covers contracts still in force on that date. Contracts concluded before that date require reasonable efforts to report intensity, with an annual account of those efforts from 5 August 2028. From 5 August 2030, the demonstration against maximum values applies to contracts concluded or renewed after 5 August 2030.
As of 27 October 2026, these remain the dates in the adopted regulation. On 14 October 2026 the Commission proposed delaying certain importer requirements, in COM(2026) 569. On 22 October 2026 the European Parliament adopted a position for a longer postponement, including later dates for some reports by EU operators. Parliament’s press release summarizes that position. Until an amendment enters into force, the adopted regulation remains the legal reference for these deadlines.
How OGMP 2.0 relates to the EU Methane Regulation
Article 28 provides two routes for demonstrating equivalent methane monitoring and reporting for imported crude oil and natural gas. Importers can rely on producer-level practices equivalent to the EU requirements, or on reporting that meets OGMP 2.0 Level 5. Both routes also require independent verification equivalent to the regulation’s requirements.
OGMP 2.0 Level 5 means reconciling a source-level emissions inventory with independent site-level measurements. Membership and a Gold Standard designation can show progress in that voluntary framework. Neither replaces the independent verification Article 28 requires, and Level 5 reporting alone does not demonstrate compliance with the import requirements.
How methane intensity requirements will apply
Methane intensity describes methane emissions relative to a defined measure of production. Under Article 29, Union producers and importers are required to report methane intensity and, later, to demonstrate that it is below maximum values the Commission sets.
The regulation gives the Commission until 5 August 2027 to adopt the calculation methodology. As of 27 October 2026, EUR-Lex does not show a delegated act establishing that methodology or the maximum values. The Commission’s September 2026 import guidance still treats the methodology as due by that date. Until the EU method is adopted, producers and importers cannot assume that an intensity figure from another inventory or certification program will match the EU figure. The emissions included, the production measure used, and the calculation method all affect the reported intensity. Understanding methane intensity explains what to check before two intensity figures are compared.
What information should producers provide to EU importers?
A producer supplying the EU may already hold much of the Annex IX information. A domestic inventory may show source-level estimates and the method used to calculate them. Measurement results, OGMP reports, leak surveys, venting and flaring logs, and a verifier’s statement may already be kept in other systems or by other teams.
Matching those records to the imported supply can take further work. The inventory may not include site-level measurements. The verification statement may cover other facilities or a different reporting period. Leak surveys and venting records may be stored apart from the emissions report. For gas bought through a trading hub, the contract documents may not name the producer or the region of production.
Non-EU producers do not submit the importer’s report to an EU authority. However, where existing records do not cover the relevant supply, facilities, or reporting period, producers may need to assemble additional information for the importer.
Validere’s regulatory air and GHG reporting capabilities support the management of emissions data and reporting across multiple regulatory frameworks.
Frequently asked questions
Does OGMP 2.0 Level 5 meet the EU Methane Regulation for oil and gas imports?
OGMP 2.0 Level 5 is one route for demonstrating equivalent methane monitoring and reporting under Article 28. Importers must also demonstrate independent verification equivalent to the regulation’s requirements. OGMP membership or a Gold Standard designation alone does not satisfy those obligations.
Who reports under the import rules, the producer or the importer?
The importer submits the report to the competent authority in the Member State where the importer is established. The producer provides the underlying information. When the exporter is a different company, the importer identifies the exporter as well.
Is a methane intensity limit already in force?
As of 27 October 2026, no maximum methane intensity value under Article 29 is in force, and EUR-Lex does not show the delegated act that would set the calculation methodology. The adopted regulation gives the Commission until 5 August 2027 to adopt that methodology. It provides for intensity reporting from 5 August 2028 and maximum-value requirements from 5 August 2030, subject to the contract conditions in the deadline section. Proposals to postpone those obligations have not entered into force.
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Darren Belgrave
darren.belgrave@validere.comDarren Belgrave is Marketing Manager at Validere, where he focuses on environmental operations, emissions management, and industrial software strategy.
