Clarifying our analysis of the EU methane regulations

Rystad Energy’s analysis of the impact of the EU methane regulations has been cited in the media repeatedly. Consequently, we want to clarify what the analysis shows and which aspects have not been part of the analysis.

The report published in December 2025 assesses a broader range of topics, including the availability of Oil and Gas Methane Partnership (OGMP 2.0) Level 5 volumes and the outstanding implementation gaps. The June report is an update, focused on identifying the volumes of OGMP 2.0 Level 5 natural gas and crude available, given the closure of the Strait of Hormuz.

An important aspect is that meeting the criteria to be OGMP 2.0 Level 5 is the first step toward compliant cargoes, but it is not sufficient. As described in the December report, a system needs to be in place for a third party to verify the measurements, and another to trace the hydrocarbons from source to the EU.

The Rystad Energy view, reiterated in the June update, is that the required OGMP 2.0 Level 5 volumes are projected to exist. The implementation gaps listed in the executive summary of our December report would have to be resolved for volumes to become compliant.

We note concerns about legal risks of importing non-compliant volumes by the industry. This is not a topic we have assessed. Neither is the impact on margins that re-routing of trade could have for EU refineries. Both are relevant discussions.

We’ve had a number of meetings with regulatory and industry stakeholders over the last few months, during which we have continued to reiterate that the question of EU Methane Regulations (MER) goes beyond the pure volumetric OGMP Level 5 analysis.

We stand by the volumetric assessments made in the reports, as well as the analysis conducted on the implementation gaps.

Note on methodology: The methodology used to arrive at OGMP 2.0 Level 2027 volumes is included in the appendix of the respective reports. The analysis is based on International Methane Emissions Observatory (IMEO) reporting for the year 2024 (published in 2025), the current Level, whether the company is on a Gold Standard Pathway, and how many years the company has been at that level.