Climate policy and greenhouse gas (GHG) accounting frameworks are evolving rapidly in 2026, creating new considerations for organizations that report emissions, manage climate risk, or pursue decarbonization goals. In the United States, the U.S. Environmental Protection Agency is reevaluating elements of the Greenhouse Gas Reporting Program and reconsidering the scientific and legal basis of the Endangerment Finding for Greenhouse Gases under the Clean Air Act. At the same time, the GHG Protocol, the most widely used corporate accounting framework for emissions, has proposed significant updates to its Corporate standards and guidance. Together, these developments could influence how companies measure, report, and manage GHG emissions in the coming years. The following newsletter highlights the key proposed changes and what they may mean for organizations preparing for regulatory and corporate climate disclosure commitments.
GHG Reporting Deadline Extended to October
The U.S. Environmental Protection Agency (EPA) has finalized a rule extending the Reporting Year (RY) 2025 deadline under the Greenhouse Gas Reporting Program (GHGRP). Facilities and suppliers subject to reporting requirements under 40 CFR Part 98 will now have until October 30, 2026 to submit their annual greenhouse gas reports. The rule, signed by the EPA Administrator Lee Zeldin on February 25, 2026, provides regulated entities with additional time to prepare submissions while broader program changes remain under consideration.
According to the EPA, the deadline extension from March 31, 2026 to October 30, 2026 is intended to ease compliance pressures as the agency evaluates the comments on proposed revisions to the GHGRP dated September 16, 2025, including the potential to significantly alter or rescind elements of the program. Importantly, this action does not modify existing data collection, calculation, or recordkeeping requirements for RY 2025; it strictly adjusts the reporting deadline. Companies must continue monitoring and maintaining required emissions data in accordance with current regulations.
For industry stakeholders, the seven-month extension offers added flexibility for data verification, internal review, and third-party assurance processes. However, organizations should remain attentive to forthcoming EPA rulemaking that may affect future reporting years or broader program obligations. Regulatory developments later this year could introduce more substantive changes, making it prudent for compliance teams to monitor EPA announcements and assess potential operational and strategic impacts.
Repeal of the GHG Endangerment Finding: What happens now?
On February 12, 2026, the U.S. Environmental Protection Agency finalized a rule rescinding the 2009 Greenhouse Gas Endangerment Finding, a landmark determination that greenhouse gases threaten public health and welfare and therefore can be regulated under the Clean Air Act. The original finding served as the legal foundation for many federal climate regulations, particularly GHG emissions standards for motor vehicles and engines. The immediate effect of this action is that engine and vehicle manufacturers will no longer have future obligations for the measurement, control, and reporting of GHG emissions for any highway engine and vehicle, including model years manufactured prior to this final rule. By repealing the finding, EPA is also signaling a broader shift in federal climate policy, with the agency stating the action could significantly reduce regulatory costs and compliance burdens.
For industry, the repeal introduces significant regulatory uncertainty. While the action removes the immediate federal basis for certain GHG regulations, it is already set to face lengthy legal challenges. Regardless of its outcome, this may result in a patchwork of state-level climate policies filling the gap. Companies should therefore monitor ongoing litigation and policy developments closely, as future court decisions or regulatory actions could reshape the federal role in GHG regulation and affect long-term compliance and decarbonization strategies. For a more detailed description and implications on this update, please refer to Trinity’s article here.
GHG Protocol Scope 2 Guidance Updates and New Accounting Approach for Electricity Sector
On January 31, 2026, the GHG Protocol closed the first public consultation for its two proposals. One proposes updates to the Scope 2 Guidance (originally published in 2015). The other introduces a new “consequential” accounting method for estimating avoided emissions resulting from actions taken in the electricity sector.
The GHG Protocol, the most widely used framework for corporate GHG accounting, is undergoing a revision of its corporate standard documents, including significant updates to the Scope 2 Guidance and introduction of a new accounting method for representing avoided emissions for the electricity sector. The Scope 2 revisions are intended to improve the accuracy, transparency, and comparability of corporate emissions inventories as climate disclosure requirements and stakeholder expectations continue to evolve. Among the most notable proposals are changes to Scope 2 guidance, including stricter requirements for renewable energy claims such as matching electricity consumption with clean energy generation on an hourly basis and ensuring that purchased renewable energy could realistically be delivered within the same power market or grid region.
If adopted, these changes could significantly affect how organizations calculate and report their greenhouse-gas emissions, particularly for companies that rely on renewable energy certificates or other market-based instruments to reduce reported Scope 2 emissions. The revisions may increase the level of data granularity required, influence renewable energy procurement strategies, and potentially raise the cost and complexity of maintaining low-carbon electricity claims.
As climate disclosure regulations and voluntary reporting frameworks continue to align with the GHG Protocol, companies may need to reassess their current GHG inventory methodologies, energy procurement strategies, and data management systems to ensure they remain consistent with the evolving standard. Organizations that proactively evaluate these potential impacts will be better positioned to adapt once the updated guidance is finalized.
A second public consultation for these proposals is expected later this year, with final publication of these updates expected in 2027. To learn more about the proposed changes and how it may impact your company, please refer to Trinity’s detailed article here.
GHG Protocol Proposes New Standard for Land Sector
The GHG Protocol recently released its first-ever Land Sector and Removals Standard, establishing a global framework for companies to account for GHG emissions and carbon removals associated with land use and agricultural activities. Historically, corporate GHG inventories have focused primarily on energy-related emissions, leaving land-sector impacts inconsistently reported despite agriculture and land use change contributing roughly a quarter of global GHG emissions. The new standard addresses this gap by providing methodologies for quantifying emissions from land use change, land management, biogenic products as well as guidance for reporting CO2 removals from land management, and geologic storage of biogenic CO2 and technological CO2 removals. Additional guidance is expected in the second quarter of 2026. The standard will take effect on January 1, 2027, and is designed to be used alongside the other existing GHG Protocol’s Corporate Scope 1 and Scope 3 standards.
The standard introduces accounting requirements for companies with agricultural supply chains or land-based operations, including those involved in the production, processing, purchase, or sale of agricultural products. Organizations must account for emissions associated with land use change (including deforestation), agricultural production activities such as livestock and fertilizer use, and land-management impacts on soil carbon. The framework also requires companies to separately report emissions and removals, introduces stronger traceability requirements across supply chains, and includes new concepts such as land carbon “leakage,” which occurs when a company’s actions indirectly shift agricultural production to locations outside their value chain. While reporting CO2 removals remains optional, companies that include removals in their inventories must meet requirements related to lifecycle accounting, data quality, traceability, and permanence. Note that forest-related emissions and removals are not included within the scope of the current standard and will be addressed at a later date.
For companies that source agricultural commodities or pursue carbon removal strategies, the new standard could significantly expand the scope and complexity of GHG accounting. Organizations may need improved supply-chain traceability, new data collection from producers, and enhanced monitoring of soil carbon or other removal pathways. As climate disclosure frameworks and net-zero standards continue to align with GHG Protocol guidance, companies with land-related activities should begin evaluating how these requirements could affect Scope 1 and Scope 3 inventories and future decarbonization strategies.
As federal climate regulation becomes more uncertain and market pressure intensifies, proactive compliance and strategic planning are critical. Trinity’s compliance and sustainability teams help companies assess regulatory exposure and risk, maintain compliance, and position their operations for resilience in a rapidly evolving climate policy environment.
If you have any questions about how the recent developments in climate regulatory policy and disclosure standards may affect your company, please contact Trinity’s local sustainability expert, Anu Krishnan, at [email protected] or call 317.451.8100.
Expert Spotlight
Anu Krishnan is a Managing Consultant and Sustainability expert based in Trinity’s Indianapolis office and supporting clients across the Midwest region and nationally. She brings more than 15 years of environmental and sustainability consulting experience across the United States.
Anu advises clients in a wide range of industry sectors on sustainability initiatives including Greenhouse Gas (GHG) accounting (Scopes 1, 2 and 3), decarbonization strategy development, climate disclosure support, and science-based target setting. She has also managed client relationships and led multidisciplinary teams on air quality permitting and compliance, regulatory assessments, and air dispersion modeling analyses.
Anu has served as an instructor for several Trinity education courses and routinely presents at webinars and industry conferences on climate and sustainability topics.
