In December 2025, New York’s Department of Environmental Conservation finalized regulations requiring businesses to report their greenhouse gas emissions. The Mandatory Greenhouse Gas Reporting Program is intended to support New York’s understanding of its emissions sources. It’s also a move to protect against anticipated federal rollbacks on climate reporting and transparency. The first round of emissions reports for the program is due in 2027, using 2026 data.
In the face of fierce federal headwinds, the state of New York is continuing to forge ahead with climate transparency measures. In December 2025, New York’s Department of Environmental Conservation (DEC) announced finalization of its , which requires businesses to provide information about their carbon emissions.?
The law is intended to improve New York’s understanding of its emissions sources and provide visibility into how the largest polluters in the state are impacting communities. It will also protect against anticipated rollbacks of climate regulations at the federal level. On September 12, 2025, the U.S. Environmental Protection Agency (EPA) .
Below, we provide an overview of New York’s Mandatory Greenhouse Gas Reporting Program, including who has to report, what information must be disclosed, and when reporting requirements take effect.
What is New York’s Mandatory Greenhouse Gas Reporting Program??
The program requires certain companies to disclose emissions annually.
The Greenhouse Gas Reporting Program is part of New York’s continuing effort to increase transparency about sources of air pollution in the state, in alignment with its Climate Leadership and Community Protection Act. Companies will submit disclosures through NYSDEC’s New York State Greenhouse Gas Reporting Tool (NYS e-GGRT), which the agency is currently developing and will support with training.?
Notably, the law does not require companies to make emissions reductions—it only mandates that they disclose their climate impact.?
Following the release of draft regulations, from April 2 through July 1, 2025, receiving more than 3,000 submissions. The program was finalized after an extensive public process. In response to public feedback, the agency updated its proposal, including extending reporting deadlines, clarifying definitions, and increasing alignment with federal regulations.?
New York Mandatory Greenhouse Gas Reporting Program - A Quick Timeline
- March 2025 - New York DEC Releases Draft of Mandatory Greenhouse Gas Reporting Program
- September 2025 - US EPA proposes ending the federal Greenhouse Gas Reporting Program
- December 1, 2025 - DEC Announces Finalization of Regulations
- December 10, 2025 - Final Program Published in State Register
- September 1, 2026 - Emissions Monitoring and Measurement Plans Due for Applicable Reporters
- December 31, 2026 - Monitoring Plans Due for Large Emissions Sources
- June 1, 2027 - First emissions reports due
- December 1, 2027 - Verification statements due for 2026 emissions
Who is Required to Report Under New York’s Law??
Companies in heavy-emitting industries will have to file annual reports.?
New York’s Program is set to impact , with a focus on heavy emitters, including the energy, agriculture, and waste sectors. Specifically, the program applies to:?
- Owners and operators of facilities in New York that emit 10,000 metric tons (MT) or more of carbon dioxide equivalent (CO2e) per reporting year. These facilities include electricity generation, stationary combustion, landfills, waste-to-energy, natural gas compressor stations, and other infrastructure
- Fuel suppliers that provide a quantity of fuel to an end user in New York that generates any amount of GHG emissions per reporting year. This includes suppliers of natural gas, liquid fuels, and petroleum products, liquefied natural gas and compressed natural gas, and coal
- Waste haulers and transporters (exporters) for which the estimated emissions from solid wastes transported to landfills or combustion facilities outside of New York exceed 10,000 MT CO2e emissions in any year
- Electric power entities that emit any GHG emissions or import megawatt hours (Mwh) into New York
- Suppliers of agricultural lime and fertilizer that supply a quantity of agricultural lime and fertilizer necessary to generate any GHG emissions per emission year; or
- Anaerobic digestion and liquid storage of waste at facilities, such as wastewater treatment plants and concentrated animal feeding operations, where wastes are imported to the facility or generated at the facility in an amount that would generate 10,000 or more metric tons of CO2e per year.?
Reporting Categories
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What Do Companies Need to Report?
New York’s Mandatory Greenhouse Gas Reporting Program requires covered entities to submit annual greenhouse gas emissions data, along with information that explains how those emissions were calculated and managed. The program is designed to standardize emissions data collection across the state and does not require emissions reductions.
At a high level, reporting requirements include:
1. Annual greenhouse gas emissions (in CO?e)
Companies must report total greenhouse gas emissions expressed in carbon dioxide equivalent (CO?e), calculated using 20-year global warming potentials (20-GWP), as specified by NYSDEC.
2. Emissions by applicable source category
Emissions must be reported by relevant source type, depending on the reporter’s classification. This may include, for example:
- Stationary combustion and process emissions at facilities
- Waste-related emissions
- Fuel volumes supplied for end use in New York
- Electricity generation or imports associated with New York consumption
3. Underlying activity data and calculation methods
Reporters must disclose the data and methodologies used to calculate emissions, including:
- Activity data (e.g. fuel volumes, waste tonnage, or electricity generated)
- Emission factors and calculation approaches
- Assumptions or estimation methods applied where direct measurement is not available
This information must be sufficient to support regulatory review and, where applicable, third-party verification.
4. Emissions monitoring and measurement documentation
Certain reporters must submit documentation describing how emissions data are collected, tracked, and reviewed, including data sources, internal controls, and quality assurance processes.?
5. Verification documentation (for large emission sources only)
Entities subject to verification must submit an annual verification report prepared by a NYSDEC-accredited third-party verifier, confirming the accuracy and completeness of reported emissions data.
What is the Timeline for Reporting??
Emissions monitoring plans are due beginning in September 2026.
Final regulations for New York’s Mandatory Greenhouse Gas Reporting Program were published in the State Register on December 10, 2025. Beginning September 1, 2026, applicable reporters must submit emissions monitoring and measurement plans to NYSDEC. Companies classified as Large Emission Sources must submit additional monitoring documentation by December 31, 2026.
The first annual emissions report is due June 1, 2027, covering 2026 emissions, with subsequent emissions reports due by June 1 each year thereafter.
Verification reports are required annually for large emission sources. Verification reports covering 2026 emissions are due by December 1, 2027, and reports covering 2027 emissions are due by December 1, 2028. Beginning in 2029, verification reports are due by August 10 each year.
Verification follows a rolling three-year cycle, consisting of a full verification in the first year and less-intensive interim verifications in the following two years. All verification must be conducted by NYSDEC-accredited third-party verifiers.
Key Reporting Deadlines at a Glance
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Preparing for New York’s Mandatory Greenhouse Gas Reporting Program
Reliable systems for managing emissions data are key.?
While the first emissions reports are not due until June 1, 2027, preparation needs to begin well in advance. New York’s program is structured around continuous data collection, defined methodologies, and, for some entities, third-party verification.?
1. Confirm whether you are a reporting entity
Start by determining whether your organization meets NYSDEC’s reporting thresholds or falls into one of the covered categories, such as facility operators, fuel suppliers, waste exporters, or electric power entities. Companies can use established carbon accounting platforms, such as 麻豆原创, to estimate emissions and help determine whether they are likely to fall within the program’s reporting thresholds.
2. Identify whether verification will apply
Verification is not required for all reporters. Companies should assess early whether they qualify as a “large emission source,” as verification thresholds differ by reporting category. If verification will apply, additional planning is required to engage an accredited verifier and assemble supporting documentation.
3. Align internally on calculation methodology
New York requires emissions to be calculated using a 20-year global warming potential. Companies with existing carbon inventories, particularly those aligned to federal GHGRP, voluntary reporting, or international frameworks, should ensure internal teams understand where New York’s requirements differ and avoid mixing methodologies.
4. Build an auditable emissions inventory for 2026
Because 2026 is the first emissions year covered by the program, companies should treat it as the first compliance year for data capture. This means identifying all relevant emission sources, activity data owners, and systems of record before the year begins, rather than reconstructing data after the fact.
5. Prepare required monitoring and measurement plans
Certain reporters must submit emissions monitoring and measurement plans by September 1, 2026, with additional requirements for large emission sources by December 31, 2026. These plans should clearly document data sources, calculation methods, internal controls, and review processes.
6. Design reporting workflows with auditability in mind
Even companies not subject to verification should expect regulatory scrutiny. Establishing clear documentation, internal review checkpoints, and change-management processes will reduce risk and make future verification or regulatory review significantly easier.?
A New Baseline for Climate Transparency in New York
In announcing its Mandatory Greenhouse Gas Reporting Program, New York joins a group of states, including California, , and , leading the push for climate transparency in the United States. The program establishes a new baseline for emissions disclosure and positions the state to better understand and manage its largest sources of climate pollution?
