Beyond Climate Policy: The Economy-Wide Repercussions of Eliminating the Greenhouse Gas Reporting Program

Commentary by Leslie Abrahams and Mathias Zacarias

Published December 15, 2025

The Greenhouse Gas Reporting Program (GHGRP) began as a voluntary program initiated during the Bush administration in 2008. In 2010, the Environmental Protection Agency (EPA) began collecting data on the emissions from qualifying facilities. Since then, the program has expanded to cover approximately 85-90 percent of total U.S. greenhouse gas emissions from over 8,000 unique sources spanning 47 industries.

A dataset of consistent, transparent, and verified emissions data is undeniably valuable for national emissions accounting. Proponents of decarbonization rely on the GHGRP to track progress toward emissions goals and monitor industry performance. But the utility of the program extends far beyond the confines of climate enthusiasts. It adds value to the broader economy in unexpected ways. Over time, GHGRP data has become embedded in federal tax credit implementation, private sector risk assessment, financial market modeling, and corporate governance-functions that extend far beyond environmental compliance.

In September, the EPA proposed eliminating reporting obligations for all but one source category-the petroleum and natural gas systems reporting would be suspended until 2034, the amended start year of the methane waste emissions charge. In the proposed rule, the EPA asserts the reporting requirements do not serve a statutory purpose and therefore do not justify the regulatory burden and administrative costs they impose on firms. The EPA could instead consider alternative programmatic revisions to reduce regulatory burdens, such as making reporting voluntary and increasing the emissions reporting threshold in a phased approach; far from reducing a few hundred million dollars annually in compliance costs, repealing the reporting program in full would materially harm U.S. competitiveness and financial market efficiency and put billions of dollars of annual U.S. investment at risk.

Industry Investment

The GHGRP plays a role in enabling companies to monetize federal energy tax credits, making it a key tool to facilitate investment in new technology deployment. A clear example is the section 45Q carbon capture tax credit. Today, the only federally recognized pathway to claim the credit uses GHGRP reporting data to verify captured, injected, or stored carbon dioxide. While the Treasury Department could theoretically develop an alternative, this would take time to design, test, and implement. Such a delay would put billions of dollars in planned carbon capture investments at risk, ranging from ethanol and ammonia facilities in the Midwest to enhanced oil recovery (EOR) operations along the Gulf Coast. For many EOR projects, 45Q is necessary to secure economic viability as oil prices drop, which is one reason why the credit was extended in the One Big Beautiful Bill.

GHGRP data also underpins investment in clean hydrogen production through the 45V hydrogen tax credit. Earlier this year, the U.S. Department of Energy allowed for hydrogen production facilities reliant on natural gas to input company-specific methane leakage data instead of national averages when claiming the hydrogen tax credit. This change would have rewarded producers with access to higher credit values when they verified their gas was sourced from a low-emissions supply chain.

Investor Portfolios

Investors use GHGRP data to inform the development of risk-adjusted portfolios. Greenhouse gas emissions data helps assess the physical and transition climate risks of their portfolio companies. It also helps assess how efficiently these companies can compete on a global scale, especially in a time of increased energy security concerns; companies with lower emissions generally have higher operational efficiency, face less exposure to volatile energy prices and supply disruptions, can more readily adapt to changing global climate regulations, and have better access to new markets.

Investors thus use GHGRP data to benchmark performance against peer companies, assess transition strategies and risks, screen portfolio companies, and track progress against stated reduction targets. The GHGRP provides reliable, consistent, and comprehensive emissions data. A 2022 survey found institutional investors spend almost $1.4 million annually "to collect, analyze, and report climate data to inform their investment decisions." Without the GHGRP data, investors would operate under more uncertainty and seek alternative verification measures that are less accurate, less comparable, and more expensive. Even if private entities attempted to self-fund an alternative data collection effort, it would be incomparable to the consistency, accuracy, and scale of public collection.

Financial Markets

The value of emissions data to investment portfolio risk management is demonstrated by market performance. Several studies have found positive correlation between company financial performance and environmental, social, and governance (ESG) factors. Recently, Morgan Stanley found that sustainable funds outperformed traditional funds in the first half of 2025, and have done so since at least December 2018. Furthermore, a study by Morgan Stanley Capital International (MSCI) introduced a new methodology to assess transition risk. It found that emissions have had a stronger relationship to performance-including corporate earnings, stock performance, and credit risk-than previously estimated. This method demonstrates that verifiable scope 1 emissions data, as is generated by the GHGRP, are foundational to transition risk models throughout financial markets.

Another recent study evaluated equity market performance based on the timing of GHGRP data release and found that emissions disclosures are priced into stock market performance at the time of release. The results confirm that emissions disclosures provide useful information to investors that is incorporated into markets in real time. This evidence suggests companies that report emissions data financially benefit from the regulatory disclosures. The study does not imply that lower emissions improve market performance, nor that companies with high emissions should hide their carbon footprint; rather, it conveys that credible information transparency provides financial benefit because it reduces investor uncertainty.

Lending and Banking

Borrowing from banks and other financial institutions is a primary source of capital for most companies. The cost of this capital is a critical metric, as it forms the basis for company investment decisions and risk management. Evidence is mounting that banks take emissions performance into account when determining loan conditions. One study found that companies that report under the GHGRP obtain lower interest rates than other comparable firms, strengthening evidence of the link between mandatory disclosures and reduced financing costs. Another study confirms the relationship between emissions reporting and reduced cost of capital, and further identifies that this correlation is only significant for firms that participate in mandatory reporting via GHGRP; the study finds that lenders historically have not taken voluntary disclosures into account to the same degree.

Insurance Markets

U.S. climate-related disasters in 2024 alone cost over $180 billion in estimated direct damages. Increasing climate risks are reshaping the insurance sector. Globally, research shows a statistical relationship between the emissions intensity of underwriting portfolios and the risk of financial instability. This market response to climate risk puts pressure on insurers to manage their underwriting strategies.

While there is not yet public evidence that insurers are systematically using facility-level emissions data to shape their underwriting activities, many insurers are moving toward voluntary disclosure, including tracking, benchmarking, and setting targets for their underwriting portfolios. One U.S. company, for example, issued new criteria for oil and gas companies in 2024 requiring them to reduce methane emissions intensity by 2030 globally or risk losing coverage. As these examples become increasingly common, the GHGRP, as a verifiable and consistent data source, could have become increasingly embedded in insurance company operational decisionmaking.

No Credible Alternatives

As these examples demonstrate, comprehensive, verified, nationally consistent facility-level emissions reporting corresponds to economic performance. Inconsistency and lower quality data would diminish these economy-wide benefits. While recission of the GHGRP would be expensive for states and the private sector as they substitute with alternative data collection mechanisms, these direct costs are not the core issue. Functionally, the precision, scale, and consistency of the GHGRP cannot be replicated outside of the federal government due to the lack of legal authority, standardization, and infrastructure to process the vast quantity of data. From a global competitiveness perspective, non-federally verified data is unlikely to be accepted by foreign governments in emerging carbon pricing schemes and other emissions intensity regulations, thereby complicating international compliance and making U.S. products more expensive abroad.

The GHGRP Is an Economy-Wide Resource

The GHGRP is not simply a reporting requirement; it is a component of the nation's economic data infrastructure. Its repeal would disrupt valuable uses of the information across financial markets, industrial investment, and risk management systems. As these cross-sector examples demonstrate, the GHGRP is not a niche data source for individual company climate accountability and cumulative U.S. inventory tracking, but a key input for foundational economic decisionmaking, both directly and indirectly underlying value creation across the economy. From individual company investment decisions to macro market performance, evidence is mounting that the verifiable emissions data published by the GHGRP provide high-value information that drives decisionmaking in real time.

The GHGRP is the only consistent, verifiable, facility-level emissions dataset in the United States. Public comments have made the case for maintaining the program for statutory purposes, state-level requirements and regulations, compliance with export laws, and public disclosure. But beyond those core climate policy-related benefits, this data underpins billions of dollars in investment decisions based on tax credit administration, and its availability lowers the cost of capital for firms, enables risk assessment, supports insurance and banking scenario analyses, and informs institutional investment strategies. Without the GHGRP, companies would operate under greater uncertainty and rely on less accurate, less consistent, and more costly private or voluntary data, raising costs for investors and reducing transparency across markets.

There is currently no substitute for the GHGRP. The EPA could consider alternative programmatic revisions, such as making reporting voluntary and increasing the emissions reporting threshold in a phased approach. Repealing the GHGRP in full and without lead time as proposed would do far more than alleviate a $300 million annual reporting burden. It would put billions of dollars of investment at risk by undermining tax credit measurement and verification pathways. It would also weaken the ability of investors, lenders, and insurers to price risk, thereby increasing cost of capital and reducing portfolio risk diversification-materially harming U.S. investment, competitiveness, and financial market efficiency.

Leslie Abrahams is deputy director and senior fellow with the Energy Security and Climate Change program at the Center for Strategic and International Studies (CSIS) in Washington, D.C. Mathias Zacarias is an associate fellow and energy transitions fellow in the Energy Security and Climate Change Program at CSIS.

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