A Note from Highwood: The views expressed in this article are those of the authors alone and do not represent the position of Highwood Emissions Management or SLR International.
OGMP 2.0 is now the leading global methane measurement and reporting standard for oil and gas, with more than 160 member companies, more than 42% of global oil and gas production, and more than 80% of LNG flows. The United Nations Environment Programme (UNEP) describes it as the only comprehensive, measurement-based international framework for the sector.
Despite significant enrollment, what began as a voluntary credibility initiative is now being pulled into the machinery of regulation, trade, finance, and commercial risk. As that happens, OGMP 2.0 faces an existential question: is the Gold Standard sufficiently robust to meet these new expectations?
In recent years, companies participating in OGMP 2.0 have invested significant resources in methane emissions measurement, data infrastructure, analysis, reconciliation, documentation, and internal controls. Some companies have made immense progress. However, as advisors to member companies, we have heard a recurring frustration: they can do the hard work, earn Gold, and still watch others manage to cut corners without obvious consequence.
Their frustration points to a deeper risk. Accountability only works when rewards and consequences match actions. A reporting program that gives the same public recognition to rigorous and superficial work will eventually train some members to do less and encourage leaders to look for something better. Managing methane already carries significant credibility risk. If OGMP 2.0 cannot clearly distinguish rigorous work from weak work, it risks enabling the very greenwashing it aims to prevent.
We are watching in real time as the EU Methane Regulation is turning MRV-based methane reporting from a voluntary exercise into a regulatory and commercial risk. Beginning January 1, 2027, importers must demonstrate that crude oil, natural gas, or coal imported into the EU was produced under equivalent MRV requirements or, for oil and gas, at OGMP 2.0 Level 5 reconciliation plus verification. Methane intensity reporting follows in 2028. A methane intensity requirement follows in 2030.
By raising the bar on operator-level methane transparency, EUMR confronts OGMP 2.0 with a choice: either adapt to meet the intention of the rule, or watch members and stakeholders turn to alternatives. The European Commission recognizes OGMP 2.0 Level 5 plus verification for EUMR import compliance. However, an ISO monitoring and reporting protocol and other third-party verification protocols are developing in parallel. The market will eventually use the pathway that sufficiently eases the implementation burden on European regulators, and addresses the risks and realities of importers, producers and market intermediaries.
Changes are required if OGMP 2.0 wants to adapt from a voluntary program to a regulatory and commercial instrument. UNEP’s review process may be (or may not be) rigorous internally, but the public signal is vague. Achieving Level 5 today communicates procedural conformance without enough emphasis or transparency placed on reporting quality. Two companies can both appear Gold while making vastly different choices on measurement coverage, representativeness, data quality, extrapolation bias, reconciliation logic, investigation of discrepancies, other assumptions, and mitigation. These differences combine to determine whether a number can be trusted.
Another risk is that perverse incentives hinder progress or compromise fairness. Companies that use state-of-the-art methane technologies often find more methane. Similarly, companies that use unbiased event extrapolation methods often report more methane. So long as ambiguity in monitoring requirements and data handling persists, the risk remains high that company-level reported values do not match true performance. The worst incentive would be a system where companies that commit to the work are penalized, while companies that avoid looking receive the same stamp of achievement.
There are specific steps that UNEP can take to adapt. Most importantly, it should be clear which companies have failed, and why. Conversely, UNEP should create official exemplars for companies doing excellent work, with enough technical detail to set a clear bar. That bar should apply consistently around the world. While achieving Gold is more difficult in some regions compared to others, UNEP must prioritize a consistent quality signal to the market, even if that means inconsistent implementation periods.
Another approach would be to include additional details in each participant’s annual public reporting that make it clear the measurement methods, measurement coverage, uncertainty, and reconciliation decisions. UNEP could publish a quality rubric for Level 5 and Gold that grades each company for measurement coverage, uncertainty, reconciliation, transparency, investigation, and mitigation. This transparency could allow outside stakeholders to better compare efforts of different participants.
Governance and implementation for any of these suggested changes is challenging. OGMP 2.0 is a consensus framework, and consensus helped it gain legitimacy. However, a framework that requires near-unanimous agreement to adapt will become obsolete in a sector where satellite data, continuous monitoring, aerial measurement, source-level methods, ISO standards, and verification expectations are moving quickly. Operators are frustrated when guidance changes through vague announcements, unofficial conversations, or late-stage reversals. Requirements must be both clear and adaptable.
UNEP needs a faster and more disciplined change-control process: versioned guidance, effective dates, rationale for changes, technical consultation, appeal paths, and clear separation between binding requirements and recommendations. Flexibility must live inside a stable governance system. Otherwise, flexibility becomes ambiguity, and ambiguity kills accountability. Years of voluntary and regulatory standards-setting experience in the GHG-reporting and sustainability fields shows that programmatic accountability relies on clear expectations and reliable, trusted enforcement mechanisms.
The widespread degree of voluntary OGMP 2.0 participation shows that operators now recognize measurement as a necessary part of a robust inventory. Before OGMP 2.0 started, many years of regional macro-scale measurements showed a pattern of higher measured emissions than reported inventories could explain. Despite significant attention on methane over the past decade, the gap persists at an international scale. Closing it will require improvements to the current system.
OGMP 2.0 may be the oil and gas industry’s best opportunity to rally around a credible methane standard. That opportunity is too important to lose. UNEP should raise the bar, make excellence visible, and make weak work harder to hide. The companies doing the hard work should want that. Regulators and buyers should demand it. UNEP should lead before the market builds the alternative.
