MARCOGAZ Response to EC Public Consultation: Draft Implementing Regulation on Templates for Methane Emissions Reporting in the Energy Sector
10 November 2026
MARCOGAZ has responded to the European Commission’s public consultation on the draft Implementing Regulation establishing templates for methane emissions reporting in the energy sector under Regulation (EU) 2024/1787.
MARCOGAZ supports a common European reporting system that is legally consistent, technically unambiguous, compatible with OGMP 2.0 and practical to implement. Its recommendations recognise the simplifications already included in the draft and stay within the obligations set by the Regulation.
The response proposes targeted improvements to the templates. These include clarifying emission-source classification, distinguishing between source-level, site-level and reconciled emissions, and adding units for emission factors. They also cover clarifying the scope of distribution-system reporting and ensuring that venting and flaring reporting is proportionate but complete.
The response raises implementation concerns as well, calling for a later data submission deadline and a transitional period until accredited verification capacity is available in every Member State.
