Overview
- Notice 2026-1 creates a contingent path for calendar-year 2025 claims if the EPA does not relaunch the e-GGRT system by June 10, 2026.
- Eligibility requires compliance with Subpart RR as in effect on December 31, 2025 and preparation of a full Annual Report consistent with those rules.
- A qualified independent engineer or geologist registered in any U.S. state must certify the report and provide an affidavit of independence under penalties of perjury.
- Taxpayers must complete all documentation and obtain the certification by the time they timely file their federal tax returns to rely on the safe harbor.
- The relief applies only to carbon oxides disposed of in secure geological storage and excludes use as a tertiary injectant in enhanced oil or gas recovery, with advisers urging early engagement of certifiers and strengthened record-keeping.