U.S. EPA Finalizes Oil and Gas Compliance Deadline Extension

Revisiting Our Previous Update

In our earlier blog post, U.S. EPA Extends Compliance Deadlines for Oil and Natural Gas Sector, we discussed the interim final rule (IFR) issued in July 2025 that provided temporary compliance relief under the 2024 Clean Air Act (CAA) methane and volatile organic compounds (VOC) standards. At the time, the extension was provisional and the regulated community questioned whether the U.S. Environmental Protection Agency (U. S. EPA) would ultimately formalize the revised timelines. That question has now been answered. On November 26, 2025, U. S. EPA issued a final rule that adopts the IFR deadlines, providing needed regulatory certainty and allowing operators to plan around a confirmed schedule.

U.S. EPA’s Rationale for Extending the Deadlines

In announcing the final rule, U.S. EPA acknowledged concerns raised during the public comment period regarding the feasibility of the original deadlines, which the agency described as “unrealistic for many operators.” U.S. EPA cited widespread supply-chain constraints, technical staffing shortages, and laboratory testing capacity limitations as reasons the earlier timeline could not reasonably be achieved without risk to ongoing field operations. These concerns were first raised by petitioners following promulgation of the original rule, who cited infeasible compliance timelines and conflicting regulatory language, prompting U.S. EPA to issue the interim final rule to provide immediate regulatory relief while they evaluated the issues raised. U.S. EPA characterized the revised deadlines as “more realistic,” reflecting a balance between environmental objectives and practical implementation challenges.

What the Final Rule Changes

The final rule confirms the compliance extensions first introduced in the July 2025 IFR, providing operators with an additional eighteen months to meet several core implementation requirements under Subpart OOOOb. The extended timeframe applies to control devices, equipment leak standards, storage vessels, process controllers, and cover and closed-vent systems. The original compliance timelines established in the IFR for meeting the emissions guidelines under Subpart OOOOb were preserved in the final rule. By calculating the revised compliance window from the IFR’s publication date, U.S. EPA has allowed operators to maintain the benefit of the time elapsed since the IFR was issued and avoids resetting any proposed compliance deadlines.

In addition to the implementation deadlines for core equipment standards, the final rule extends requirements for performance testing and continuous monitoring for flares and enclosed combustion devices. The IFR initially included a 120-day extension for these control devices. After evaluating comments submitted during the public review period, U.S. EPA increased the extension to 180 days, citing supply-chain limitations, fabrication schedules, and installation restrictions identified by operators during the comment process.

This ruling also revises reporting deadlines under the NSPS annual reporting framework. U.S. EPA has established a one-time 360-day window for annual reports that would have come due before the revised compliance dates. Following this transition period, annual reports will be due 90 days after the end of each compliance period, beginning with the first compliance cycle following the extended deadline. U.S. EPA noted that this approach is intended to reduce ambiguity during the transition while establishing a defined annual reporting cadence for future years. The revised deadlines are presented in the following table:

U.S EPA estimates that the finalized extensions will apply to “hundreds of thousands of oil and gas sources across the country,” including well sites and midstream operations. According to the agency’s final rule analysis, aligning the deadlines with current implementation capacity is expected to reduce near-term compliance costs, with projected savings of approximately $750 million over an eleven-year period. U.S. EPA attributes the cost reduction primarily to the ability to schedule compliance work alongside planned maintenance cycles rather than accelerating projects on compressed schedules.

What This Means for Operators

For operators, the finalized rule does more than extend deadlines. By codifying the updated compliance timelines, U.S. EPA has resolved prior regulatory uncertainty and established a defined compliance schedule. Notably, the final rule specifies that no annual report under Subpart OOOOb will be due before November 30, 2026, providing affected facilities with additional time to implement the emissions guidelines, specifically for facilities whose first annual report would otherwise have been due between July 2025 and the effective date of the final rule. With these deadlines clarified, facilities can better align methane-control implementation projects, continuous monitoring system deployment, and leak detection programs with internal planning cycles and capital strategies. Although the rule does not alter the substance of the underlying standards, U.S. EPA’s action acknowledges operational constraints and provides additional time to achieve compliance without disrupting production.

Looking Ahead

With the final rule in place, owners and operators of affected facilities should reassess internal compliance plans and ensure that project timelines reflect the updated deadlines. Although the federal rule has been finalized, its implementation will differ across state environmental agencies. Facilities located in states with approved implementation plans for 40 CFR Part 60, Subpart OOOOb should closely monitor ongoing state rulemaking and evolving environmental policies that may affect their compliance obligations. U.S. EPA has signaled its intent to continue providing guidance during the rollout of the revised requirements and expects affected facilities to use the extended timeline to make steady progress toward full compliance.

What This Means for Your Organization

U.S. EPA’s final rule helps resolve the uncertainty created by the July IFR; however, it also shifts the focus to execution. Now that compliance dates are established, facilities should begin translating these regulatory timelines into concrete operational steps—reviewing procurement needs, confirming contractor availability, planning for monitoring and testing activities, and ensuring staff are prepared for upcoming requirements. In addition, because state plans will ultimately drive how Subpart OOOOb is administered, differences among state-level timelines and expectations may influence strategic planning, permitting schedules, and budgeting. Remaining engaged with state rulemaking will be essential to anticipating obligations and preventing downstream delays.

Need Help Understanding How this Affects You?

If you are wondering how U.S. EPA’s final rule will affect your facility or ongoing projects directly, please reach out to your ALL4 project manager or contact Ashley Brooks at abrooks@all4inc.com.