The road ahead: Defending the Greenhouse Gas Reporting Program to safeguard stability, competitiveness and credibility

EPA’s recent actions affecting long-standing policies — including its decision to overturn the Endangerment Finding — have introduced significant uncertainty into the regulatory landscape. Defending the Greenhouse Gas Reporting Program (GHGRP) against EPA’s proposal to eliminate it is now more important than ever for businesses, investors, and the markets they rely on.

Across recent Federal Reserve Bank of Dallas Energy Surveys and the latest Gulf Coast Energy Outlook, executives have delivered a consistent message: persistent policy uncertainty is weighing on investment decisions and day-to-day operations.

In the face of growing uncertainty, preserving the GHGRP is an immediate and practical step businesses and policymakers can take to safeguard a framework that provides stability, competitiveness and credibility.

The GHGRP rollback creates immediate risks for businesses

GHGRP is the data backbone underpinning federal programs, tax incentives, capital planning, supply-chain contracting, investor analysis and international market access. Weakening it would have immediate consequences.

• Fragmented reporting requirements: Eliminating or weakening GHGRP would not reduce costs. It would shift reporting into a mix of state, private, lender, investor and international systems — increasing complexity and compliance costs.
• Loss of comparability: Without a consistent federal methodology, benchmarking across companies and sectors becomes more difficult, undermining capital allocation decisions.
• Jeopardizing tax policy: Numerous federal and state programs rely on GHGRP data or aligned methodologies. Weakening the program creates ripple effects across compliance systems.
• Competitive Distortion: Companies that have invested in robust data systems and emissions performance risk being undercut by underperformers operating with less transparency.
• Market expectations persist despite regulatory rollbacks: Investors, lenders and trading partners continue to demand credible emissions reductions that require robust emissions reporting and verification.

GHGRP is a steady anchor in a sea of regulatory volatility

As EPA moves to roll back long-standing regulatory structures, preserving credible, consistent emissions reporting becomes even more important.

EPA recently extended the GHGRP reporting deadline for Reporting Year 2025, citing its ongoing reconsideration of the program. While the extension applies only to this reporting cycle, it underscores the broader uncertainty facing businesses that rely on GHGRP data for capital planning, tax compliance, supply chain contracts and international market access.

While thoughtful alternative or sector-specific frameworks can provide valuable data, GHGRP remains the only program that delivers economy-wide, government-backed continuity that markets currently rely on.

For more than 15 years, GHGRP has provided:

• A mandatory, economy-wide reporting baseline
• Consistent methods applied across sectors, with regular, transparent updates that allow comparability over time
• Public, government-backed data trusted by companies, markets and regulators
• A foundation for investment decisions, tax credits and trade

That’s why the response to EPA’s proposal to roll back GHGRP has been so striking. Across oil and gas, manufacturing, utilities, aviation, fuels, finance and technology, companies and trade associations have warned that eliminating GHGRP would not reduce reporting burdens. It would fragment them, increase costs and undermine trust, while jeopardizing access to tax credits and global markets.

Nothing else measures up to GHGRP

In response to EPA’s proposal, there have been discussions about standing up alternative reporting efforts. These conversations highlight the importance stakeholders place on maintaining data reporting and continuity.

But even the most well-designed alternatives cannot substitute for GHGRP, because they lack key attributes that only a federal program can provide:

• Mandatory participation: Applies to facilities in specific sectors, including large oil and gas, industrial and power facilities, with annual emissions above 25,000MT CO2e. Voluntary systems cannot ensure comprehensive coverage or prevent cherry-picking, preventing accurate benchmarking across companies.
• Economy-wide scope: Sector-specific efforts cannot support cross-sector comparability or national inventories.
• Government credibility: Markets, regulators and trading partners rely on federally backed data gathered using methods developed through robust and transparent regulatory processes as well as verification and enforcement.
• Durability and consistency: Private frameworks and policy priorities change; GHGRP has provided continuity across administrations providing insights into emissions trends over time.
• Transparency: Public access extends beyond reported emissions to much of the underlying data supporting emissions calculations, building trust and enabling accountability.

GHGRP remains the only program that provides this combination of coverage, credibility and transparency for reliable, government-backed emissions reporting. While other reporting systems exist, such as the Clean Air Markets program for power plants, they do not deliver the economy-wide, multi-sector comparability that GHGRP provides.

Voluntary commitments matter, but they are not enough

Recent analyses, including findings highlighted in Pledges to Progress 2025, highlight a core lesson from the past decade: voluntary initiatives play a critical role in innovation and leadership, but they do not deliver system-wide results on their own.

That lesson is bolstered by independent, real-world measurement. Recent satellite analyses, including data from MethaneSAT and GOSAT, show that jurisdictions with clear, enforceable standards are delivering sustained emissions reductions even as energy production continues to grow. These observations provide strong evidence that consistent rules, transparent data and effective implementation can deliver significant reductions while industry continues to thrive — underscoring the value of durable, government-backed reporting programs like GHGRP.

Progress at scale requires predictable rules, comparable data and accountability for leaders and laggards alike.

GHGRP provides the data backbone that helps make both voluntary and regulatory efforts credible. Weakening it would undercut not only government oversight but also market confidence, and the very voluntary initiatives many companies rely on to demonstrate leadership.

Business leadership is needed now more than ever

This heightened risk environment raises the stakes for everyone who depends on regulatory stability, including businesses making long-term capital investments. Companies, investors and trade associations face a clear choice: remain silent as foundational systems erode, or take concrete steps to safeguard stability and demonstrate leadership.

With regulatory uncertainty on the rise, businesses can step up in concrete ways to protect the GHGRP and maintain systems and continuity that markets depend on.

Practical actions include:

• Champion regulatory stability and GHGRP continuity: Encourage trade associations and policymakers to maintain GHGRP as the federal baseline for emissions reporting and avoid actions that weaken long-standing federal programs. Predictable, evidence-based policy protects investment certainty and market credibility.
• Maintain robust, auditable data systems: Regardless of shifting deadlines or regulatory timelines, ensure operational emissions data remains accurate, aligned with GHGRP methodologies, centralized and consistent across reporting frameworks to preserve credibility with investors, regulators and trading partners.
• Align reporting with market expectations: Ensure reporting methods remain compatible with global frameworks (e.g., EU Methane Regulation, OGMP 2.0) to safeguard commercial access and investor confidence.
• Integrate data into investment and risk decisions: Use transparent, comparable metrics to guide capital allocation, portfolio management and long-term strategic planning.
• Engage proactively on policy: Provide constructive feedback to regulators and lawmakers to encourage predictable, science-based rules that support long-term stability.

Taking these steps signals to markets that your company prioritizes transparency, accountability and efficiency, turning a challenging regulatory environment into a leadership opportunity.