CA-GREET 4.0 True-Up Credits and the 4:1 Penalty

Environmental ConsultingEnvironmental Consulting
July 21, 2026
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The March 30 deadline for 2025 Annual Fuel Pathway Reports, the first cycle under CA-GREET 4.0, has passed, and margin-of-safety elections are now final. What happens next matters just as much: CARB will issue true-up credits after verification completes in fall 2026, applicable to all 2025 transactions, while pathway holders whose verified operational CI exceeds their certified CI face a 4:1 deficit penalty.

Where the 2025 AFPR Cycle Stands

2025 AFPRs were due March 30, 2026, submitted in CA-GREET 4.0 with a parallel CA-GREET 3.0 submission to document CI differences attributable solely to the calculator transition. Some input definitions changed between calculator versions, and site-specific modifications under 4.0 may require additional CARB approval. Margin-of-safety (MOS) elections made in the filing are final. The true-up and penalty provisions were adopted in the 2025 LCFS amendments.

What Happens in Fall 2026

True-Up Credits

After 2025 AFPR verification completes in fall 2026, CARB will issue true-up credits applicable to all Q1–Q4 2025 transactions, allowing pathway holders to claim credit value based on actual operational CI.

The 4:1 Deficit Penalty

However, when a verified operational CI exceeds the certified CI, the pathway holder incurs deficits at a 4:1 ratio. Pathway holders who underestimated operational CI or did not choose an aggressive MOS face a materially asymmetric outcome.

What Pathway Holders Should Do Between Now and Verification

Action Checklist

  • Run a CI gap analysis comparing the current CI value against your verified CI.
  • Reconcile any input-definition changes between CA-GREET 3.0 and 4.0 that affect your pathway’s calculated CI.
  • Model the 4:1 downside scenario so leadership is not surprised by the deficit obligation.

Trinity’s Clean Fuels Practice provides CA-GREET 4.0 CI modeling, CI gap analysis, and LCFS verification support. To talk through your pathway position, please email Alex Marcucci.

Trinity provides the environmental compliance expertise we need to keep our business flowing. The amount of collaboration between us has established a high level of trust. Trinity is always looking out for our best interest.

Brent Jensen/Frazier
Manufacturing Director of EHS and HR

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