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Practice Areas
New York Implements Greenhouse Gas Reporting for 2026
In December 2025, the New York State Department of Environmental Conservation (NYSDEC) finalized regulations establishing a Mandatory Greenhouse Gas (GHG) Reporting Program, codified at 6 NYCRR Part 253. The program creates a statewide framework for collecting emissions data to support the implementation of the Climate Leadership and Community Protection Act. NYSDEC has emphasized that the program is for data collection and inventory development and does not itself require emissions reductions or allowance purchases.
The reporting program applies to several categories of “reporting entities.” These include facilities emitting at least 10,000 metric tons of carbon dioxide equivalent annually; suppliers of fossil fuels and fuel products delivered into New York; electric power entities responsible for electricity imported into or exported from the state; certain waste transporters exporting waste out of New York; and other specified categories such as agricultural lime and fertilizer suppliers and certain anaerobic digestion and liquid waste storage operations. For many supplier categories, reporting is triggered by any quantity of covered fuel, while higher thresholds determine whether additional requirements, such as verification, apply. Covered facilities must report emissions from stationary combustion as well as process, vented, and fugitive sources, supported by detailed activity data.
Key compliance deadlines include submission of Emissions Monitoring and Measurement Plans for applicable reporters by September 1, 2026; GHG Monitoring Plans for large emission sources by December 31, 2026; the first Emissions Data Report by June 1, 2027 (covering calendar year 2026); and, where applicable, third-party verification statements by December 1, 2027.
Affected companies must assess applicability across reporting categories, designate authorized responsible representatives, implement systems to capture required emissions and activity data beginning in 2026, prepare and submit monitoring plans, and, where applicable, engage an accredited verifier well in advance of the first reporting and verification deadlines in 2027. Failure to comply with the Mandatory GHG Reporting Program can result in enforcement under the Environmental Conservation Law, with reporting violations treated as continuing offenses.
