FNB Gas on the European Commission’s Draft Implementing Act for the EU Methane Regulation

FNB Gas welcomes the opportunity to comment on the draft reporting templates submitted by the European Commission for consultation from October 9 through November 6, 2026. This comment refers to the documents published for this consultation as well as to the current draft of the “Methane Emissions Database” (MTDB), which was developed in accordance with Article 30 of the Methane Emissions Regulation (MER) and presented to industry stakeholders in October 2026.

Members of FNB Gas had the opportunity to test the features of an initial version of the MTDB. This statement also takes into account the experiences of the test users in order to help optimize the report templates.

FNB Gas recommends, in particular, the following changes to the current draft of the implementing regulation, the draft reporting templates, and the Methane Transparency Database (MTDB):

• Clear reporting channels and appropriate reporting deadlines: Entities subject to reporting requirements need legal certainty regarding to whom they must submit their reports. In addition, reporting deadlines and procedures within the MER should be harmonized.
• Attribution of Emissions to Operators: It must be clear who is required to report. To avoid double-counting of emissions, operators of facilities should be required to report, but not owners who do not perform operational functions.
• Allow the continued use of existing report templates: In addition to a new reporting system based on the MTDB, it should still be permissible to use existing report templates such as OGMP 2.0.
• Transitional Provisions for Verification: Due to the lack of accreditation systems and accredited verifiers, appropriate transitional provisions are necessary to ensure that reporting entities can fulfill their reporting obligations.
• Clear Definitions and Dimensions: The terminology used in the MTDB and in the report tables in the annex to the draft implementing regulation should be aligned with existing technical standards and guidelines.

The statement is available in the download section.