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.
