Methane

Federal Methane Rules in 2026: What Oil and Gas Operators Need to Do Now

February 26, 2026

By: Elizabeth McGurk

Federal methane regulations for the oil and gas industry currently have an incredible amount of uncertainty. With rule delays, proposed reconsiderations and differing mandates across local, state and international jurisdictions, there is a complex web for upstream, midstream and downstream operators to sift through.   

While deadlines have shifted, many methane compliance obligations remain, and interest from the public and other stakeholders continues to increase. Operators that stay grounded in defensible measurement and documentation will be positioned to adapt regardless of future changes. 

This article outlines U.S. federal methane regulations affecting oil and LNG facilities in 2026. For other regulatory drivers, see our U.S. State, Canada and Global methane regulations to watch.

Given the dynamic nature of methane regulations, we will continue to update this content periodically to reflect rule changes and our insights. Please refer to the date above for the latest revision. 

Key takeaways 

  • The 2009 GHG endangerment findings were repealed
  • Most federal methane requirements remain in effect, with only select compliance deadlines under NSPS Subpart OOOOb and Emission Guidelines OOOOc extended
  • Greenhouse Gas Reporting Program (GHGRP) reports for calendar year 2025 emissions was extended to October 30, 2026, including expanded Subpart W requirements
  • The Methane Waste Emissions Charge (WEC) is delayed until reporting year 2034

GHG endangerment findings: repealed, with litigation ahead 

In February 2026, the EPA finalized the repeal of the 2009 GHG endangerment findings. The two endangerment findings listed under Clean Air Section 202(a) determined that: (1) GHGs threaten public health and welfare and (2) GHGs from motor vehicles and engines cause or contribute to this endangerment. These findings did not impart any requirements on stationary or mobile emissions sources; they were the foundation for major federal climate rules, beginning first with GHG vehicle standards and then extending to GHG regulations for stationary sources, including the oil and gas industry. 

Implications for operators: 

GHG regulations for stationary sources remain in effect until such time that other rules are modified or repealed. Operators should ensure that their compliance programs remain intact and that existing monitoring, work practice and reporting practices are consistent with applicable regulations. See below for more details on the status of federal methane regulations for the oil and gas industry. 

NSPS Subpart OOOOb and EG OOOOc: partially delayed, reconsideration of selected technical revisions under review

In 2025, the U.S. Environmental Protection Agency (EPA) finalized an interim rule extending several compliance deadlines under NSPS Subpart OOOOb and EG OOOOc. Importantly, only the provisions explicitly listed in the rule were delayed. All other monitoring, inspection and work practice requirements remain in force. 

Key extended deadlines

The following requirements have compliance dates extended to 2026 or 2027: 

June 1, 2026
Continuous monitoring of vent gas heating value for flares and enclosed combustion devices (or 14-day exclusion testing)

November 30, 2026
Initial annual report submission

January 22, 2027
  • Total Organic Compound testing on enclosed combustion devices
  • No identifiable emissions inspections for covers and closed vent systems
  • Low-emitting valve packing replacement for leaking valves
  • Zero-emissions process controller replacement
  • Storage vessel legally and practicably enforceable emissions limit determinations and 30-day production period determinations
  • Super emitter program implementation
  • State implementation plan submissions under EG OOOOc are also due

Note that separate reconsideration of technical revisions related to associated gas flaring and NHV monitoring for flares and enclosed combustion devices is under review. Those requirements are in force until such time as the proposed rule changes are finalized. 

Implications for operators

  • All provisions of NSPS Subpart OOOOb not listed above are in force, including many monitoring and work practice requirements 
  • An initial annual report will be due for many operators in November 2026
  • Engineering teams should use 2026 to finalize hardware upgrades, monitoring systems and controller replacements before January 2027
  • Documentation systems should align inspection, monitoring and emissions determinations with future annual reporting requirements

Operators that treat 2026 as a transition year, rather than a pause, will avoid compressed compliance timelines in 2027.

GHGRP: reporting obligations remain, submission deadline extended while reconsideration under review

In September 2025, EPA proposed reconsideration of the Greenhouse Gas Reporting Program. The proposal would suspend Subpart W reporting for most segments until reporting year 2034 and remove obligations for natural gas distribution.

EPA received more than 53,000 comments and has not finalized the rule. Until final action occurs, GHGRP remains in effect. 

In February 2026, EPA extended the 2025 reporting deadline from March 31 to October 30, 2026. This deadline extension is likely to give the agency time to address comments and finalize rulemaking prior to the 2025 reporting deadline.

For more information on GHGRP Subpart W revisions, read our white paper.

Implications for operators:

For calendar year 2025 emissions 

  • Reports are currently due October 30, 2026 
  • Updated Subpart W requirements issued in 2024 apply 
  • Operators must report additional source categories 
  • New emission factors are required for certain sources 
  • Measurement-based data must be used when available, including data collected for other regulatory or voluntary programs 

Subpart C reporting for stationary fuel combustion sources continues to apply. EPA has signaled future rulemaking on combustion reporting, but no changes are currently in effect. 

For compliance teams, this means data management and QA/QC protocols in 2025 directly influence regulatory exposure. 

Methane Waste Emissions Charge: 10-year delay 

Congress delayed implementation of the Methane Waste Emissions Charge through revisions to the Clean Air Act. Fees will first be assessed on 2034 reported emissions, payable in March 2035.  

The statutory framework established by the Inflation Reduction Act remains.  

Implications for operators:

Because the fee is calculated using Subpart W data, current reporting practices establish the baseline for future financial exposure. 

Strategic guidance for 2026 

Federal regulatory timelines may shift. However, state, provincial and international regulatory pressure is increasing. Regulatory, commercial and public stakeholders are maintaining their focus on the methane footprint associated with the energy industry. Methane regulations are increasingly anchored in emissions detection and measurement, informing strategy.  

Oil and gas operators should: 

  • Avoid reactive program changes driven by short-term policy shifts 
  • Anchor methane programs in defensible measurement and documentation 
  • Align operational controls with both regulatory and voluntary frameworks 
  • Monitor regulatory development, including federal litigation and state implementation plans  

A resilient methane strategy reduces compliance risk, supports investor and stakeholder expectations and preserves operational flexibility.

To understand EPA requirements for individual states, consult our U.S. State methane article. For cross-border and export-related obligations, see our Canada and International articles.

Elizabeth McGurk HeadshotElizabeth McGurk
Methane Sector Leader
As Montrose Environmental’s Methane Sector Leader, Elizabeth leads complex, cross-disciplinary initiatives focused on methane quantification, mitigation, and regulatory strategy. With thirteen years of experience in air quality consulting—specializing in oil & gas and GHG accounting—she brings deep technical insight and a passion for data-driven emissions reduction. At Montrose, she guides global OGMP 2.0 initiatives, designs measurement pilots aligned with the revised U.S. EPA Subpart W rule, and delivers impactful training on methane management and the current regulatory environment. Elizabeth also contributes to the IOGP working group developing ISO standards for EU Methane Regulation compliance, helping shape the future of methane management worldwide.

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