Published on Wednesday, April 29 2026
Authors : TM&C Fuels Regulatory Team

EPA’s mid-March release of final 2024 RFS compliance data, combined with EMTS records through 2025 and the March 27, 2026 Set 2 final rule, provides the clearest picture the market has had in several years regarding the program’s current position and future obligations.

That clarity doesn’t necessarily simplify things. The data confirms that the 2025 compliance year was tighter than many market participants had assumed, while the finalized 2026 and 2027 renewable volume obligations (RVOs) represent a meaningful step-change relative to recent program history. Understanding what that means for obligated parties and renewable fuel producers requires looking beyond the headline figures.

What the 2025 Data Shows

EPA data indicates that 23.1 billion RINs were generated in 2025. After retiring approximately 1.6 billion RINs associated with exported renewable fuel, about 21.5 billion RINs remained available for domestic compliance.

Using the adjusted EIA petroleum consumption data of roughly 176.2 billion gallons, the implied 2025 RVO requirement is about 23.4 billion RINs. In other words, the available RIN generation did not fully cover the obligation.

Importantly, that gap was not evenly distributed across RIN categories. Where the shortfalls occurred — and the reasons behind them — will influence how the significantly higher 2026 and 2027 obligations interact with the existing production base.

Interpreting the RIN Bank

The reported 3.5 billion RIN bank entering 2025 requires some context.

A meaningful portion of that bank reflects retroactive revisions to prior compliance years. Following recent small refinery exemption (SRE) decisions, refiners revised historical compliance filings, which in turn altered reported RVO obligations and the resulting RIN bank calculations. However, additional changes in the data files going back to 2018 suggest something beyond SRE activity alone may have contributed to those revisions — a dynamic worth examining more closely. Those adjustments don’t come with announcements — they are embedded within EPA’s data files, and their cumulative effect can materially shift the compliance picture for participants building models or assessing market positions.

Based on currently available data, the carryover bank entering 2026 is approximately 1.6 billion RINs, with an additional variable still pending. Unresolved 2025 SRE petitions could add roughly 1 billion RINs depending on how those decisions ultimately resolve.

Set 2 Final Rule: A New Obligation Level

EPA’s Set 2 final rule, released March 27, establishes renewable volume obligations at the highest levels in the program’s history.

2026 Total Renewable Fuel RVO: 25.82 billion RINs

2027 Total Renewable Fuel RVO: 25.98 billion RINs

Both levels exceed the proposed targets.

The increases are not evenly distributed across categories:

Biomass-based diesel rises from 5.36 billion RINs in 2025 to 8.86 billion in 2026. Advanced biofuels increase from 7.33 billion to 10.82 billion. Conventional ethanol remains flat at 15 billion gallons for both years.

The key consideration is that these obligations are being implemented against a 2025 compliance year where generation fell short of the implied requirement. While the final rule provides regulatory certainty on the targets, the question now shifts to whether the current production base and feedstock supply can support those levels.

The Variables Still in Motion

Several factors will shape how the 2026 compliance year ultimately develops: resolution of pending 2025 SRE petitions and any resulting retroactive revisions to EPA compliance data; actual renewable fuel generation by category, particularly given the meaningful increase in advanced and biomass-based diesel obligations; and EPA’s use of compliance flexibility mechanisms, including the proposed cellulosic waiver for 2025, which could influence effective obligation levels.

The Set 2 rule closes an important chapter in RFS regulatory uncertainty. What remains unresolved is whether production capacity, feedstock availability, and market economics can meet obligations that are now at unprecedented levels for the program. The dynamic between production capability and regulatory targets, along with the limited buffer of the RIN bank, may lead to tightness in the market and will likely define the compliance landscape through 2026 and into 2027.