These Frequently Asked Questions (FAQ) relate to the implementation of the 2024 LCFS amendments (//ww2.arb.ca.gov/rulemaking/2024/lcfs2024). The FAQs will be updated periodically.

Frequently Asked Questions (updated August 11, 2025)

How will the amended 2025 carbon intensity (CI) benchmarks apply to quarterly reporting and credit generation?

The amended 2025 carbon intensity benchmarks came into effect on July 1, 2025, and apply to fuels supplied in Q3 2025 and beyond. Benchmark values included in the LCFS regulation sections 95484(d) Table 1 for gasoline, 95484(e) Table 2 for diesel, and 95484(f) Table 3 for jet fuel will apply to credit generation calculations included in various sections, including section 95486.1 of the LCFS regulation, starting with Q3 2025 quarterly fuel transaction reports due by December 31, 2025.

Given there are two different 2025 CI benchmarks applicable to different parts of 2025 – is CARB also implementing two different crude CI scores from “Table 9” in 2025?

Yes. For Q1 and Q2 2025 quarterly fuel transactions, the pre-amendment[1] (#_ftn1) Table 9 values apply. For Q3 and Q4 quarterly fuel transactions, the amended Table 9 values apply as shown in the current regulation that went into effect on July 1, 2025.[2] (#_ftn2)

Will the credit true-up provisions apply to all 2025 reported transactions?

Section 95488.10(b) of the LCFS regulation specifies that when a CI is verified at a lower value than it was certified and reported, credits representing the difference will be issued to fuel reporting entities. These “true-up credits” will be issued starting with the 2025 data year and will apply to all 2025 transactions (Q1 – Q4 quarterly fuel transaction reports). CARB will issue the true-up credits after 2025 Annual Fuel Pathway Report (AFPR) verification completes in the fall of 2026.

When does the CI exceedance deficit obligation begin?

Deficit obligations resulting from CI exceedances will apply to all 2025 reporting (Q1 – Q4). The CI exceedance deficit obligation will be generated after AFPR verification completes in the fall of 2026. Section 95486.1(g) of the LCFS regulation specifies that when a CI is verified at a higher value than it was certified and reported, a deficit obligation equal to 4 times the exceedance based on reported fuel volumes and credit generation will be added to the fuel pathway holder's LRT-CBTS account. Any fuel pathway holder without an LRT-CBTS account generating a deficit obligation must create an LRT-CBTS account.

To reduce the chance of having a CI exceedance, a fuel pathway holder may request to add a margin of safety (MOS) to their pathway CI during the AFPR verification process each year, pursuant to section 95488.10(a)(6) of the LCFS regulation. A pathway holder may establish a conservative margin of safety (MOS) in fall of 2025 to be applicable to both the 2025 and 2026 data year in order to ensure no CI exceedance for the 2025 data year. To facilitate an implementation transition associated with the midyear (July 1, 2025) effective date of the amendments, any MOS established for the 2025 data year in the fall of 2025 will be applied to fuel transactions reporting for purposes of credit generation following 2025 Annual Fuel Pathway Report verification (in 2026). 

When can I request to add or update a conservative margin of safety (MOS) for my fuel pathway CI?

According to sections 95488.4(a) and 95488.10(a)(6)(B), a fuel pathway applicant or fuel pathway holder may request to add a margin of safety during the initial pathway certification or when replacing a previously certified CI with the verified operational CI during the AFPR process. Please see the previous question regarding CI exceedance deficit obligation for additional information.

[1] (#_ftnref1)https://ww2.arb.ca.gov/sites/default/files/2020-07/2020_lcfs_fro_oal-approved_unofficial_06302020.pdf (//ww2.arb.ca.gov/sites/default/files/2020-07/2020_lcfs_fro_oal-approved_unofficial_06302020.pdf)

[2] (#_ftnref2)https://ww2.arb.ca.gov/sites/default/files/2025-07/2025_lcfs_fro_oal-approved_unofficial_07012025.pdf (//ww2.arb.ca.gov/sites/default/files/2025-07/2025_lcfs_fro_oal-approved_unofficial_07012025.pdf)