January 12, 2026
If you participate in the Renewable Fuel Standard (RFS) program, whether as a renewable fuel producer, obligated party, exporter, or other regulated entity, you are required to designate a Responsible Corporate Officer (RCO) with the U.S. Environmental Protection Agency (EPA).
The RCO plays a pivotal role in ensuring the accuracy, legality, and integrity of all compliance activities under the RFS. But what exactly does it mean? And who is eligible to serve in this role? Below, we break down the essentials.
What Is a Responsible Corporate Officer (RCO)?
The Responsible Corporate Officer is the individual legally accountable for the information your company submits to EPA within the RFS program. This includes attestations, quarterly reports, annual filings, facility registrations, and engineering reviews.
In short, the RCO is the person EPA holds responsible for the truthfulness, timeliness, and completeness of all compliance documents. They are the final signatory on key RFS filings, and their certification carries legal significance under federal law.
What Does an RCO Do?
RCO responsibilities include:
- Certifying reports and transactions submitted through EPA’s CDX and DCFUEL systems.
- Ensuring compliance with all RFS requirements, including recordkeeping and accurate RIN generation or separation.
- Overseeing internal controls which support the integrity of data submitted to EPA.
- Reviewing and approving engineering reviews, registrations, and amendments.
- Serving as the main compliance point of contact if EPA has questions or initiates an audit or investigation.
The EPA expects the RCO to have sufficient authority and oversight to ensure the whole company complies with the RFS, not just one department or business unit.
Who Can Serve as an RCO?
The EPA has maintained a consistent and strict interpretation of who qualifies as an RCO. Generally, the RCO must be an individual at the highest corporate level, such as:
- CEO
- President
- COO
- CFO
- Managing Member (for LLCs)
- Corporate Officer with executive-level authority
The Agency is increasingly reluctant to accept mid-level managers, compliance staff, consultants, or non-officers for this role.
EPA expects the RCO to be someone with the legal and operational authority to ensure corporate compliance, not someone who manages day-to-day tasks.
If a company does not have traditional C-suite titles, the RCO must still be the individual with ultimate decision-making authority for the organization.
If your RCO leaves the company or is no longer able to sign reports, update EPA immediately. Only the RCO can legally certify compliance documents; operating with an outdated RCO on file can create delays and compliance risks.
Why the RCO Role Matters
EPA views the RCO as the gatekeeper of compliance for each regulated entity. Because RINs have market value and the RFS program can involve complex reporting and verification, the Agency wants to ensure someone with genuine organizational authority is accountable for RFS activities.
By Tori Reese, Compliance Advisor