What is Disposición Nº 1/26?
In March 2026, Neuquén’s Subsecretaría de Cambio Climático issued Disposición Nº 1/26, establishing the procedure for greenhouse gas emissions reporting for the province’s upstream oil and gas sector.
The regulation operationalizes Neuquén’s broader GHG Monitoring and Mitigation Program, moving operators toward a more standardized approach for quantifying, documenting, reporting, and ultimately verifying emissions.
For operators, the biggest takeaway is simple:
Emissions reporting is becoming more structured, more granular, and more rigorous over time.
The first report covers emissions generated during calendar year 2025 and must be submitted in September 2026.
Who needs to report?
The procedure applies to the upstream exploration and production sector in the Province of Neuquén.
Operators must establish organizational and operational boundaries for their emissions inventory and account for emissions associated with operations under their control.
One distinction is particularly important:
The 9,000 kBOE/year threshold does not simply mean “report” or “don’t report.”
Production level affects how requirements progress, including the minimum level of quantification and when third-party verification requirements apply.
That means operators should understand both:
1. Whether their operations fall within the reporting framework
and
2. Which quantification and verification requirements apply to their production level
What emissions need to be reported?
The reporting framework covers both direct and indirect greenhouse gas emissions associated with upstream operations.
Scope 1: Direct emissions
This includes emissions from sources such as:
- Stationary and mobile combustion
- Flaring
- Venting
- Fugitive emissions
- Other direct operational sources
Scope 2: Indirect energy emissions
Operators must also account for indirect emissions associated with purchased energy.
The procedure establishes specific requirements for purchased electricity and the methodologies used to calculate and report those emissions.
What changes with methane and LDAR?
Methane is an especially important component of the new reporting framework.
Fugitive emissions must increasingly be supported by more granular quantification, while LDAR programs are incorporated into the province’s broader emissions monitoring and mitigation approach.
For the first reporting period, operators at or above the 9,000 kBOE/year production level are expected to present information on LDAR activity already being performed.
Neuquén also plans to further define technical LDAR criteria, including monitoring frequency and leak-repair prioritization.
In other words, LDAR cannot live in a completely separate operational silo from your emissions reporting process.
What are the quantification levels?
One of the most important elements of Disposición Nº 1/26 is its progressive approach to emissions quantification.
Rather than expecting every operator to immediately meet the most granular measurement standard, Neuquén establishes increasing requirements over time.
The framework defines multiple levels of quantification, with higher levels representing greater data granularity and measurement sophistication.
The requirements get more rigorous over time
The regulation establishes a progressive implementation schedule through 2030, with requirements varying based on production.
For the first 2025 inventory, operators can continue using company-specific quantification methodologies previously reported during the pilot stage.
That flexibility does not last indefinitely.
Beginning with later reporting periods, minimum quantification levels become more prescriptive.
What about third-party verification?
Verification requirements also follow the progressive framework.
For operators with production at or above 9,000 kBOE/year, third-party verification is incorporated from the first reporting cycle based on the verification processes already being performed.
Requirements continue to evolve as the quantification framework progresses.
For operators below the threshold, verification follows a different implementation schedule.
This makes one capability increasingly important:
Traceability.
An emissions number is only as defensible as the data, methodology, assumptions, calculations, and documentation behind it.
What should operators be doing now?
September may sound like a reporting deadline. Operationally, however, the work needs to happen well before the report is submitted.
Operators should already be asking:
- Do we know which assets and emission sources need to be included?
- Can we locate the source data required for each calculation?
- Are our quantification methodologies documented?
- Are our Scope 1 and Scope 2 calculations aligned with the reporting requirements?
- Can we connect LDAR activity to fugitive emissions reporting?
- Do we have a consistent QA/QC process?
- Can every reported number be traced back to supporting evidence?
- Are we prepared for verification where required?
- Do we know how our requirements will change over the next several reporting cycles?
How ready are you for September?
Knowing what the regulation requires is one thing.
Knowing whether your data, methodologies, documentation, and reporting processes are ready is another.
Take the Neuquén Methane Reporting Readiness Assessment
Evaluate your current reporting readiness, identify gaps, and understand what you should prioritize before your first mandatory submission.
Build a reporting process that can evolve with the regulation
Disposición Nº 1/26 isn’t just creating a new reporting deadline. It establishes a pathway toward increasingly granular, traceable, and verifiable emissions reporting.
That creates a challenge for operators relying on disconnected spreadsheets, manually assembled inventories, or emissions data spread across multiple teams and systems.
Envana helps operators centralize emissions data, apply consistent quantification methodologies, maintain traceability from source data through reported results, and build inventories designed to support evolving reporting and verification requirements.
This article is provided for informational purposes only and does not constitute legal or regulatory advice. Organizations should review the official requirements and seek appropriate professional guidance regarding their specific reporting obligations.