On 14 October 2026, the European Commission published a legislative proposal (COM(2026) 569 final) to postpone certain obligations under Regulation (EU) 2024/1787 (the EU Methane Regulation) by one year. The proposal follows growing industry concerns over the practical difficulties around implementation of the Regulation amid continuing disruption to global energy supplies.

The proposed postponement relates to the monitoring, reporting and verification (MRV) requirements for importers under Article 28, as well as the methane intensity requirements for importers and EU producers under Article 29. The Commission has emphasised that the changes are limited in scope and do not alter the Regulation's substantive requirements or environmental objectives.

The proposal follows the Commission's two Recommendations (published on 20 July 2026) concerning compliance solutions and the application of penalties under the EU Methane Regulation. For further analysis of those Recommendations, see our earlier blog post here.

Background: why is the Commission proposing a postponement?

The EU Methane Regulation entered into force on 4 August 2024, establishing requirements to measure, monitor, report, verify and reduce methane emissions in the energy sector, including leak detection and repair obligations and restrictions on venting and flaring. It also introduces obligations for importers of crude oil, natural gas and coal placed on the EU market.

These importer obligations are being phased in: information-reporting requirements under Article 27 have applied since 5 May 2025, and will be followed by the MRV-equivalence and methane intensity requirements under Articles 28 and 29. It is this second phase that the Commission now proposes to postpone.

The Commission's proposal comes against the backdrop of significant disruption to global energy markets following the closure of the Strait of Hormuz and interruptions to other energy export infrastructure in the Persian Gulf since February 2026.

The EU Methane Regulation does not prohibit energy imports, but the Commission acknowledges importers' concerns that they may be unable to secure sufficient supplies meeting the Regulation's MRV requirements by 1 January 2027, putting them at risk of penalties.

What would change under the proposal?

The Commission proposes amendments to four provisions of the EU Methane Regulation:

  • Article 28(1): MRV equivalence for new and renewed contracts

Currently, from 1 January 2027, importers must demonstrate that contracts concluded or renewed on or after 4 August 2024 cover only crude oil, natural gas or coal subject to MRV measures equivalent to those required under the Regulation at producer level.

The proposal would postpone this requirement by one year. Importers would therefore be required to demonstrate MRV equivalence for supplies from 1 January 2028, with the first report due by 31 May 2029, and annually thereafter.

  • Article 28(2): Existing contracts (concluded before 4 August 2024)

For supply contracts concluded before 4 August 2024, the Regulation requires importers to undertake all reasonable efforts to ensure that the relevant supplies are subject to equivalent MRV measures.

The existing requirement for importers to use all reasonable efforts to ensure MRV equivalence would remain unchanged. However, the first report on those efforts would be postponed to 31 May 2029, covering the previous calendar year. Where efforts have been unsuccessful, importers must explain why and identify the steps they have taken.

  • Article 29(1): Methane intensity reporting

The deadline for importers and EU producers to report the methane intensity of crude oil, natural gas and coal placed on the EU market would move from 5 August 2028 to 5 August 2029, with subsequent reports due annually by 31 May, covering supplies made during the previous calendar year. The existing reasonable-efforts approach for contracts concluded before 4 August 2024 would be retained.

  • Article 29(2): Maximum methane intensity values

The deadline for demonstrating that methane intensity is below the maximum values to be established by the Commission would move from 5 August 2030 to 5 August 2031, with subsequent annual reports due by 31 May. The proposed requirement would apply to supplies under contracts concluded or renewed after 5 August 2030.

What would remain unchanged?

The proposal would not affect the information-reporting obligations under Article 27, which have applied since 5 May 2025, or the Regulation's other requirements relating to methane emissions monitoring, leak detection and repair, and restrictions on venting and flaring.

Additional time to address implementation challenges

Beyond concerns over energy security, the Commission identifies several practical reasons for the proposed postponement.

The additional time is intended to allow Member States to complete their national penalty regimes, enable national accreditation bodies to accredit independent verifiers and give competent authorities further time to assess and recognise compliance solution providers.

This follows the Commission's publication of two Recommendations on 20 July 2026:

  • Recommendation (EU) 2026/1834, which provides guidance on compliance solutions, including optional model contractual clauses and approaches to demonstrating compliance in complex supply chains.
  • Recommendation (EU) 2026/1835, which recommends that Member States refrain from imposing certain penalties under Article 33(5)(m)–(o) for breaches of importer obligations due in 2027, 2028 and 2029, except in cases of fraudulent non-compliance. This effectively recommends a three-year penalty grace period.

Unlike the proposed legislative amendment, the Recommendation on penalties is non-binding and does not alter the underlying compliance obligations. The October proposal would go further by formally postponing certain obligations, rather than merely recommending flexibility in their enforcement.

The proposed postponement would provide additional time for these compliance arrangements to be developed and implemented. However, the effectiveness of the extended timetable will depend on the availability of recognised compliance solutions, accredited verifiers and the necessary reporting infrastructure.

The Commission has indicated that it will continue monitoring both implementation of the Regulation and the security of energy supplies. Any outstanding issues may also be considered as part of the Regulation's review under Article 36(1), which is due by 1 January 2028.

What does this mean for importers and supply contracts?

Whilst the proposal would provide welcome additional preparation time for importers and other market participants, it does not resolve all the practical challenges associated with the EU Methane Regulation.

In particular, importers may still face difficulties obtaining reliable methane emissions data from upstream producers, securing independent verification and demonstrating MRV equivalence across complex international supply chains.

For contracts concluded before 4 August 2024, the Commission's FAQs clarify that the reasonable-efforts requirement is assessed on a case-by-case basis. Competent authorities will consider whether importers have taken timely and appropriate steps, explored feasible alternatives and acted consistently with relevant industry practices. Such efforts may include seeking amendments to existing supply contracts. Importers should therefore be able to document the steps taken, even where they have been unable to secure the necessary information or contractual commitments.

Parties negotiating or reviewing supply agreements should consider whether their contractual compliance provisions adequately reflect the proposed timetable and reporting requirements.

More broadly, contractual arrangements dealing with information sharing, access to upstream emissions data and the allocation of compliance risks will remain important, particularly where suppliers cannot guarantee MRV equivalence due to limited control over upstream operations or reliance on third-party information. These challenges will persist regardless of whether the proposed postponement is adopted.

Next Steps

The proposal will now be considered by the European Parliament and the Council under the ordinary legislative procedure. If adopted, the amending Regulation would enter into force on the twentieth day following its publication in the Official Journal of the European Union.

The Commission has called for swift adoption to provide legal certainty ahead of the approaching January 2027 deadline. Until the amendments enter into force, however, the existing obligations and deadlines remain applicable. Importers should therefore continue their compliance preparations while monitoring the legislative process.


Key contacts

Rebecca Major photo

Rebecca Major

Partner, Head of Energy, Europe, Paris

Youssef Kassem photo

Youssef Kassem

Knowledge Lawyer, Germany

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Europe EU regulation Energy Energy Rebecca Major Irina Akentjeva Youssef Kassem Andrew Robinson