IOGP Europe’s assessment of the European Commission’s recommendations under the EU Methane Regulation and the continued need for targeted amendments

Dear Ambassador,
IOGP Europe and the oil & gas sector remain committed to supporting the EU’s methane reduction objectives and to working constructively with Member States and EU institutions to achieve a proportionate, effective and legally robust implementation framework.

The Commission’s recommendations published on 20th July 2026 are welcome recognition that practical challenges remain in implementing the Regulation while safeguarding Europe’s security of supply is critical.

However, they do not, on their own, provide the legal certainty and predictability required by companies, competent authorities and Member States. We appreciate that these concerns have been already raised by Member States in recent discussions, including by the 17 EU Member States delegations supporting the non-paper on EU Methane Regulation and 15 Energy Ministers who vocally addressed the issue at the Energy Council on 26th June 2026 and almost 20 delegations during the COREPER meeting on 15th July 2026. In these discussions, Member States recognised the structural challenges in the Regulation’s implementation framework and called urgently for targeted amendments of the regulation.

Recommendations on optional model clauses and compliance pathways

IOGP Europe welcomes the Commission’s recommendation on compliance pathways, in particular, the recognition of compliance solutions in line with industry proposal, including constrained book-and-claim approaches. However, their effectiveness will depend on such systems being fully operational and accessible across all exporting regions.

With less than six months remaining before key import requirements enter into force, companies are already negotiating crude oil and gas imports contracts now and face significant challenges in developing and operationalizing the necessary compliance systems, particularly across complex international supply chains. While the Recommendation sets out 14 criteria for compliance solutions, further detail will be needed to provide certainty as to which existing schemes are considered consistent with those criteria. Developing that clarity is likely to take additional time, leaving companies with an even shorter period to implement compliant solutions before the importer obligations apply.

Lastly, we would like to highlight that key compliance barriers still remain despite these recommendations. While monitoring and reporting pathways are developing, verification requirements remain a major bottleneck due to the lack of recognised standards and uncertainty around third-country verification frameworks (including verification methodologies, verifier capacity, accreditation) and pending secondary legislation. As a result, importers still lack a reliable way to demonstrate full compliance for many supply sources, creating ongoing legal, contractual, and reputational risks.

Recommendations on penalties

The Recommendation's recognition that Member States may extend the same grace period for penalties to Union oil and gas producers where necessary to safeguard security of energy supply is a positive step.
However, as the Methane Regulation remains fully applicable, companies continue to face legal uncertainty and risks associated with potential non-compliance. The suspension of penalties should therefore be matched by a corresponding three-year postponement of the implementation deadlines through targeted amendments to the Regulation. This would ensure consistency between the enforcement approach and the underlying legal obligations, while providing the necessary timeframe to establish effective compliance systems.

This recommendation acknowledges that security of supply considerations may justify temporary regulatory flexibility and should also serve as a basis for targeted amendments to the domestic provisions in the EU Methane Regulation, ensuring this principle is embedded in binding legislation and applied consistently across Member States.

Targeted amendments remain essential to ensure legal certainty and security of supply

IOGP Europe therefore encourages Member States to continue supporting the introduction of fast-tracked targeted amendments, in particular those articles related to import requirements in Chapter V of the EU Methane Emissions Regulation that depend on global availability of compliance tools like verification, accreditation and certifications.

Moreover, targeted amendments should be also introduced to key requirements under the domestic provisions, including Article 12, Article 14 and Article 19. Such amendments would preserve the EU’s methane reduction ambition while ensuring practical implementation, maintaining a level playing field between EU producers and international suppliers, and providing the legal certainty necessary for both domestic operators and importers to meet their obligations while supporting secure and reliable energy supply.

With the recommendations now published, it is clear why industry, represented by 75 organisations and companies, key oil and gas supplier countries and a majority of Member States have continued to raise concerns regarding legal certainty, implementation and security of supply. There is still time to introduce the necessary amendments, but action is needed urgently, as every week of delay makes an orderly solution more difficult and commercial decisions are already being taken now.

Recommendations cannot amend the binding obligations and deadlines set out in the Regulation. Companies would therefore continue to face legal and reputational risks while relying on non-binding guidance to manage compliance risks. Fast-tracked targeted amendments remain the only robust solution to align obligations, timelines with the reality of compliance options and enforcement, ensuring a clear and predictable framework for companies, Member States and authorities.

Signed

François-Régis Mouton de Lostalot
IOGP Europe, Managing Director