Regulation
What Neuquén requires from upstream operators.
Through Resolution 258/2025 (Official Gazette 4417, April 1, 2025) the province created a greenhouse gas monitoring program for oil and gas activity, regulated by Disposition 1/26 (Official Gazette 4563, April 10, 2026) and ratified by Resolution 610/26 (Official Gazette 4570). The technical procedure is annex IF-2026-00937453, 38 pages long. Everything rests on provincial Climate Action Law 3454. The national framework and the province’s own actions are in the carbon footprint tool.
Who and what
All operators, for 100% of what they operate.
Covered: upstream operators in Neuquén, which report everything they operate (operational control), by asset or block. Midstream and downstream are excluded for now.
What is reported: tonnes per year of CO₂, CH₄ and N₂O and their equivalent, using IPCC AR6 100-year global warming potentials: CO₂ = 1, CH₄ = 29.8, N₂O = 273. Scope 1 is mandatory (combustion, venting, flaring, fugitives and other). Scope 2 from the 2026 inventory, using CAMMESA’s grid factor. There is no Scope 3.
A single size cutoff: 9,000 kBOE per year. Above it, “large”: verification and LDAR from the first inventory, level 3 in 2028 and level 4 from 2029. Below it, “small”: more gradual requirements.
De minimis: sources up to 5% of the total can be excluded, calculated at least at level 2. No one can go below a level already reported or below the schedule’s minimum.
Levels
Levels are about method, not size.
From 1 to 5, from the roughest estimate to on-site measurement. Level 1 is prohibited for operators; level 5 is voluntary and earns recognition from the Undersecretariat.
A single emissions figure per asset or block per industry segment. PROHIBITED for operators.
Emissions grouped by source segment (stationary and mobile combustion, venting, flaring, fugitives, other) with general methodologies per category. Minimum reporting floor and minimum level for de minimis calculations.
Mandatory from: 2027 inventory (filed September 2028) for companies < 9,000 kBOE/year; maintained in the 2028 inventory
Emissions by detailed source type (engines, heaters, tanks, etc.) with generic emission factors from compendia or protocols and available activity data (measurements, records, engineering calculations or estimates).
Mandatory from: 2027 inventory (filed September 2028) for ≥ 9,000 kBOE/year, 100% of material sources; 2029 inventory (Sept. 2030) for < 9,000 at 50% of material segments; 2030 inventory (Sept. 2031) for < 9,000 at 75% of material sources
Emissions by detailed source with company-specific emission and activity factors (source-level measurement and sampling, simulation, detailed engineering calculations). Applies to CH4 only.
Mandatory from: 2028 inventory (Sept. 2029) at 50% of material sources; 2029 inventory (Sept. 2030) at 75%; 2030 inventory (Sept. 2031) at 100%. Only ≥ 9,000 kBOE/year.
Site-level measurements (top-down: drones, light aircraft, vehicles) at a statistically representative frequency, reconciled with the Level 4 sum following guidance such as OGMP 2.0 TGD 'Reconciliation and Uncertainty'. CH4 only. Voluntary: grants a recognition document and use of a seal owned by the Climate Change Undersecretariat.
Milestones
Dates that matter.
- 2025-04-01Res. 258/25 publishedNeuquén Official Gazette 4417
- 2026-04-10Disposition 1/26 published with the procedureNeuquén Official Gazette 4563
- 2026-04-30Res. 610/26 published (ratification)Neuquén Official Gazette 4570
- 2026-09First mandatory report (2025 inventory) and 2025 LDAR reportIF pp. 28 and 30
- 2026-12-31Deadline set by the IF to define the standardized methodology per level, 2027-2030 verification criteria, LDAR frequencies and the mitigation plan procedureIF pp. 5, 28, 31, 33
- 2027-04Approximate end of the one-year extension of the midstream/downstream pilot stageDisposition 1/26, art. 4 (first)
- 2027-092026 inventory with Scope 2 and 2026 LDAR reportIF pp. 22-24, 28, 30
- 2027Assessment of base year, metric and provincial 2030 targetsIF p. 32
- 2028Mitigation plans filed by operators that did not have oneIF p. 32
Still to be defined
What the province still has to regulate.
- Standardized methodology per level and 2027 to 2030 verification criteria (stated deadline: December 31, 2026).
- LDAR campaign frequency and the mitigation plan procedure (to be filed during 2028 by those without one).
- Base year and targets (2027).
- The official reporting template (provincial Excel template), which has not been published.
- Which production year defines the segment for each inventory. The Observatory uses the inventory year itself, annualized if not complete. See methodology.