The University of Texas at Austin Energy Emissions Modeling and Data Lab (EEMDL) recently finalized and released the first independent verification protocol explicitly designed to be consistent with the EUMR.1 The protocol includes an accompanying technical reporting protocol. Below, Highwood explains how this protocol fits into the current EUMR rulemaking process, how it is likely to shape the compliance pathways Member State Competent Authorities establish, and how it gives operators additional clarity as they stand up an EUMR-ready methane management programs.
Potential Impact on EUMR Compliance
The EUMR regulatory process is multi-phased and complex. The European Commission developed the initial rule and issues the regulation’s implementing and delegated acts, while Member States carry out actual implementation2. As of the date of this blog, outstanding actions are in process both at the European Commission and national level: the European Commission still must issue the implementing and delegated acts that will clarify rule requirements, and each Member State still must establish the national legislation needed to enact the rule. The Network of Competent Authorities EU Methane Regulation Expert Group continues to interface with the European Commission to clarify EUMR implementation and to support and review the outstanding acts.
Member States and their appointed Competent Authorities face a difficult position: they must enact national legislation and establish administrative processes that meet EUMR requirements while they wait for numerous other acts from the EU commission that clarify requirements. Outstanding items include, among other things, identification of applicable standards for methane quantification (i.e. ISO and CEN, which are still in draft form). Competent Authorities need this information to design their national regulatory programs, and its absence challenges authorities that often lack technical expertise and experience with methane regulation development or enforcement.
Because the EUMR applies to imported products and thus influences operations outside of Competent Authorities’ jurisdictions, the rule’s independent verification component is especially critical to effective enforcement.3 Competent Authorities will ultimately determine whether reports filed by importers satisfy EUMR requirements as part of the rule implementation process.4
Member State Competent Authorities will therefore likely treat the EEMDL protocol as an important resource, whether or not they formally designate it as part of an EUMR compliance pathway.5 Third-party verification will be crucial for EUMR implementation, and because the EEMDL protocol is the first one written for the rule, we expect it to influence national EUMR legislation and Competent Authorities’ discussions with the European Commission as the EU continues to clarify requirements. In the absence of finalized methane quantification ISO and CEN standards, the associated EEMDL measurement and quantification protocol could similarly shape the direction of EUMR compliance.
Simplified representation of EUMR regulatory process and current state 6
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One critical question for verifiers, especially those outside of the EU, remains unresolved: the EUMR requires independent verifiers to hold accreditation consistent with the regulation and the established legal framework for accreditation within the EU. 7 8 The EEMDL verification protocol outlines how to perform verification under EUMR requirements, but it does not provide a pathway to verifier accreditation beyond citing EUMR Article 9. Ultimately, Member States and their associated national accreditation bodies are responsible for setting accreditation pathways.
Recommendations
For energy exporters, commercial market access is both the greatest potential risk and potential advantage the EUMR presents. Operators without EUMR-compliant programs may risk losing contracts, whereas those with compliant programs may see increased demand for their product. Operators who export to the EU simply cannot afford to wait until the EU and member states resolve all EUMR regulatory uncertainty to establish their methane MRV programs. The EEMDL Technical Reporting Protocol can further organize methane MRV programs in a manner that allows for assurance to be conducted. While it has not been formally approved for use, it is the most fit-for-purpose technical resource for EUMR monitoring and reporting practices. Developed through a global stakeholder process, it should be used as a best-practice document, particularly by operators with EUMR exposure.
EUMR compliance process and applicable deadlines
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EU importers must submit their first EUMR importer MRV reports by May 31, 2028, covering full 2027 calendar-year production. Building a verification-ready methane quantification program that meets EUMR requirements takes significant time and effort. Operators must:
- Collect relevant source- and site-level emissions data throughout 2027,
- Prepare an emissions inventory that reconciles source- and site-level data, and
- Finalize their sampling plan and methane quantification data so both are verification-ready before the reporting deadline.
Even when a program is designed to be verification-ready, the reasonable assurance verification process alone can take several months.
The EEMDL EUMR verification protocol is technically robust and designed specifically for EUMR compliance. More than 200 organizations across the global oil and gas supply chain reviewed it before finalization. 9 The verification protocol provides guidance on applicability, boundaries, level of assurance, materiality, specific performance of verification assessments, and reporting. Its companion measurement and quantification protocol addresses boundaries, source categories, source- and site-level quantification, reconciliation, reporting, and quality assurance.
Although some of the details may shift as the EU Commission and Member States continue to release new guidance and legislation, operators should view the EEMDL protocol as an important tool in developing EUMR-aligned methane management programs today.
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Sources
1 Tullos, E. 2026. A Protocol for Independent Verification of Methane Emissions of Crude Oil and Natural Gas Placed on the European Union Market. Version 1.0, August 2026. Center for Energy and Environmental Systems Analysis, The University of Texas at Austin, Austin, TX, USA. (European Union Methane Regulation: Verification & Reporting Protocol — CEESA, last accessed August 2026).
2 Regulation (EU) 2024/1787 Article 4), Regulation – EU – 2024/1787 – EN – EUR-Lex, last accessed August 2026.
3 Olczak, M. 2026. How is the EU Methane Emissions Regulation implemented in practice? Insights from competent authorities and early enforcement experience. June 2026. The Oxford Institute for Energy Studies. (NG-205-EU-Methane-Emissions.pdf, last accessed August 2026).
4 Verification requirements listed in Regulation (EU) 2024/1787 Article 28(5)(a), Regulation – EU – 2024/1787 – EN – EUR-Lex, last accessed August 2026.
5 It is unknown whether Competent Authorities will pre-clear a verification protocol.
6 Adapted from: Olczak, M. 2026. How is the EU Methane Emissions Regulation implemented in practice? Insights from competent authorities and early enforcement experience. June 2026. The Oxford Institute for Energy Studies. (NG-205-EU-Methane-Emissions.pdf, last accessed August 2026).
7 Regulation (EC) No 765/2008, Regulation – EU – 2008/765 – EN – EUR-Lex, last accessed August 2026
8 Regulation (EU) 2024/1787 Article 9), Regulation – EU – 2024/1787 – EN – EUR-Lex, last accessed August 2026.
9 European Union Methane Regulation: Verification & Reporting Protocol — CEESA, last accessed August 2026.
