September 16, 2026
It can be confusing for participants in the Renewable Fuel Standard (RFS) to determine which deadline extensions apply, and how they impact them. For non-Obligated Parties, such as renewable fuel blenders and producers, EPA’s recent deadline extension might impact their RIN management strategy – but it does not impact their compliance deadlines.
Who’s Impacted by the Deadline Extension? And Why?
Obligated Parties are required to retire RINs in quantities that meet EPA’s Renewable Volume Obligation (RVO) for the year. These are more commonly referred to as blending mandates. If EPA is delayed in setting the blending mandates or EPA modifies the mandates through other policy decisions, then Obligated Parties need time to adjust, hence deadline extensions for their Annual Compliance Report.
Because other annual, quarterly and monthly compliance reports under the RFS are not dependent on RVOs, the deadlines for these reports are not extended. This is why EPA did not change deadlines for RFS participants who are strictly RIN generators, blenders, and/or traders. Deadlines also did not change for most other reports for Obligated Parties, just the Annual Compliance Report.
Deadline Extensions Becoming Expected
For Obligated Parties, deadline extensions for Annual Compliance Reports have occurred so frequently that EPA revised the code in its Set 2 Rule issued in March of this year. Under the new rule, the deadline for RIN retirement and the Annual Compliance Report is whichever date is the latest:
- March 31 of the subsequent calendar year.
- The next quarterly reporting deadline after the date of the subsequent compliance year’s renewable fuel standards (i.e., RVOs) become effective.
- The next quarterly reporting deadline after the annual compliance reporting deadline for the prior compliance year.
Policy Decision on Small Refinery Exemptions (SREs)
Even with these newly defined deadlines, EPA has been forced to extend the 2025 Annual Compliance report deadline beyond these parameters. This time it was due to a policy decision that impacted compliance with the RVOs. On August 31, EPA made decisions on 34 SRE applications. EPA announced 18 full exemptions and 11 partial exemptions, with the remaining denied or ineligible. Along with the exemptions, EPA announced it would return the RINs to those parties and extend the annual report compliance deadline by one month.
So where do the RFS compliance deadlines stand? As of September 1, here’s the rundown:
Obligated Party Annual Report Compliance Deadlines
2025 Compliance Year
- Annual Report: October 1, 2026
- Annual Attestation: June 1, 2027
2026 and 2027 Compliance Year
These deadlines are on schedule with no extensions issued (yet).
- Annual Report: March 31 of subsequent year
- Annual Attestation: June 1 of subsequent year
Staying Ahead of It
When EPA issued decisions on the 2025 SRE applications in August, they also proposed reallocating 100 percent of the difference between the projected and actual exempted volumes for 2025 SREs into the 2026 and 2027 RVOs. This proposal is expected by the end of October 2026. Additionally, there are four petitions for SREs each in 2026 and 2027 and more could be coming.
Small Refinery Exemption Petitions for 2026 and 2027, and EPA decisions on 2025 petitions.
EPA may not always reallocate RINs. But any time exempted RINs are reallocated, it changes the RVO. Depending on what reallocations are proposed and when they are finalized, the Annual Compliance Report deadline the impacted years could be extended to the “next quarterly reporting deadline” or beyond.
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