On January 22, 2026, the Environmental Improvement Board (EIB 25-23) concluded its deliberations with a unanimous vote to adopt 20.2.92 NMAC – Clean Transportation Fuel Program. With this action, New Mexico becomes the fourth state to enact a clean fuel standard program, joining California, Oregon, and Washington.
The program establishes an aggressive compliance trajectory, requiring a 20% reduction by 2030. After 2030, the standard will increase by 1% annually, ultimately reaching a 30% reduction requirement by 2040.
The accelerated compliance schedule through 2030 is based on modeling assumptions that electric vehicle (EV) electrification will serve as the primary compliance driver, supporting both light- and heavy-duty vehicle transitions. New Mexico’s ZEV mandate is scheduled to take effect in 2027 and was designed to align with California’s ZEV program. However, implementation uncertainty remains, as the California ZEV mandate is currently under EPA review and subject to legal dispute. If New Mexico’s ZEV mandate is delayed or invalidated, the current compliance modeling may require significant revision.
Structurally, the program aligns closely with the existing clean fuel programs in California, Oregon, and Washington. One notable distinction is the program registration fee structure: New Mexico will assess a $3,000 annual fee for each deficit generator and credit generator, and a $500 fee for all other registered parties. Backstop aggregators are exempt from registration fees.
The reporting period begins April 1, 2026, with the initial compliance period extending through December 31, 2027. This 21-month window is intended to provide market participants sufficient time to adapt to program requirements and establish compliance processes.
The program will accept alternate fuel pathway carbon intensity scores through a re-certification process and will also allow for the development of New Mexico-specific novel Fuel Pathway Codes (FPCs) as outlined in the program’s published FPC flow chart. Third-party verification will be required beginning September 15, 2028, and annually thereafter for fuel pathways, quarterly reporting, and project-based credits.
Trinity’s Fuels Compliance team is closely following implementation of New Mexico’s Clean Transportation Fuel Program. If you need assistance navigating program requirements, evaluating compliance strategies, or preparing for reporting, fuel pathway certification, and verification obligations under this or other state clean fuel programs, please contact Alex Marcucci.
