The Undersecretariat of Climate Change, under the Ministry of Tourism, Environment, and Natural Resources, published Disposition 1/2026 in the Official Gazette of the Province of Neuquen on 10, 2026.
 

1. Background

The Disposition approves the Greenhouse Gas (GHG) Emissions Reporting Procedure applicable to the upstream segment of the hydrocarbon industry. It also extends one year the pilot stage applicable to the midstream and downstream segments, which currently do not have an equivalent reporting procedure.

The Disposition builds upon the creation of the Greenhouse Gas Emission Monitoring and Mitigation Program for the Oil and Gas Sector, established through Resolution 258/25, pursuant to Provincial Law 3454 on the Provincial Climate Action Regime. The Program was created to identify, quantify, control, and verify GHG emissions generated by those carrying out hydrocarbon activities in the Province of Neuquen. For this purpose, it established a pilot stage aimed at sectoral diagnosis, developing a reporting procedure, and preparing a sectoral mitigation plan, followed by an implementation stage. During this stage, obligated parties must submit third-party verified emissions reports and mitigation plans.
 

2. The Procedure

The Procedure applies to all companies, concessionaires, operators, or temporary joint ventures (UTEs) involved in the exploration and production of conventional and non-conventional hydrocarbons in the Province of Neuquen. Further, the Procedure establishes the organizational and operational boundaries that obligated parties must comply when preparing their GHG emissions inventories and reports for the upstream sector.

Regarding organizational boundaries, the Procedure identifies the assets and facilities that must be included in the reporting inventory and establishes criteria for allocating emissions in cases involving shared facilities, assets operated by third parties, and other configurations typical of the sector.

Regarding operational boundaries, the Procedure distinguishes between direct emissions (Scope 1) and indirect emissions (Scope 2), defining their scope in accordance with internationally recognized practices. Direct emissions include those generated by sources under the operational control of the obligated party within its assets or facilities, while indirect emissions mainly refer to those associated with energy consumption. The Procedure also introduces the concept of de minimis sources, defined as emission sources that, due to their relatively low contribution to the total emissions of an asset, may be excluded from the main emissions accounting for mitigation purposes.

 It also structures GHG quantification and measurement methodologies into progressive tiers, which vary in terms of level of detail, accuracy, and technical complexity. The applicability of each tier is linked to the type of emission source, the gas reported, and the scale of the obligated party’s production, in accordance with the gradual implementation schedule (2025–2030) the Disposition establishes.

Obligated parties must submit their data annually using a standardized format referred to as the Template (Excel spreadsheet). The Procedure provides for third-party verification of reported emissions and establishes general guidelines for the submission of verified reports.

The need to define a baseline year will be assessed during 2027 together with the provincial metrics and mitigation targets for the sector by 2030, based on the verified GHG emissions reports submitted by companies.

External verification of the 2025 and 2026 GHG emissions inventory must be submitted by those companies that have already carried it out or have it planned for corporate-related reasons, whether as part of a sustainability report or, ideally, as part of the GHG emissions inventory report for the Province of Neuquen. The verification schedule and the provincial criteria applicable for the years 2027–2030 will be defined during 2026 and timely communicated to obligated parties.

The regime provides for specific treatment of methane emissions, for which it establishes advanced levels of quantification and measurement. In this context, the Disposition incorporates the Leak Detection and Repair Program (LDAR) as a tool to identify, quantify, and mitigate fugitive emissions.

Finally, the Disposition creates the Monitoring, Review, and Update Committee of the Monitoring and Mitigation Program, tasked with providing technical assistance to the enforcement authority in the analysis, periodic evaluation, and proposal of improvements to the Procedure and its supplementary instruments.