New York State Mandatory GHG Reporting: Requirements, Deadlines & Compliance Guide

New York State has finalised its mandatory greenhouse gas reporting programme, creating a new compliance obligation for facilities, fuel suppliers, and other covered entities operating in the state. The rules — formally codified as 6 NYCRR Part 253 — were adopted under the Climate Leadership and Community Protection Act (CLCPA) and took effect following a December 2025 finalisation process.

The first emissions reports are due June 1, 2027, covering calendar year 2026 activity. But several earlier deadlines — including an emissions monitoring plan due September 1, 2026 — mean that preparation needs to start now.

Legal basis and programme context

New York's mandatory GHG reporting programme is established under the Climate Leadership and Community Protection Act, signed in 2019. The CLCPA set legally binding targets: 40% reduction in GHG emissions from 1990 levels by 2030, and 85% by 2050, with net-zero economy-wide emissions by 2050.

The reporting programme exists to give the state accurate baseline data against which to measure progress toward those targets. Emissions data submitted under 6 NYCRR Part 253 feeds into the state's official GHG inventory and informs CLCPA compliance planning.

The programme is administered by the New York State Department of Environmental Conservation (NYSDEC). Reporting is conducted through the NYS Greenhouse Gas Reporting Tool (NYS e-GGRT), which is currently in development and expected to be operational ahead of the 2027 reporting deadline.

Who must report — the six covered categories

6 NYCRR Part 253 defines six categories of covered entities. Organisations should review all categories, not just the most obvious ones, since several apply broadly:

• Facilities. Any facility whose operations generate 10,000 or more metric tons of CO₂-equivalent (MT CO₂e) annually. This threshold applies to greenhouse gases from direct combustion, industrial processes, and other on-site emission sources combined.
• Natural gas suppliers. Any entity that supplies natural gas in New York State, regardless of the quantity supplied.
• Liquid fuels and petroleum product suppliers. Any entity supplying liquid fuels or petroleum products in New York State, regardless of volume.
• Compressed or liquefied natural gas suppliers. Any entity supplying CNG or LNG in New York State.
• Coal suppliers. Any entity supplying coal in New York State.
• Waste haulers. Any waste hauling entity whose activities generate estimated GHG emissions exceeding 10,000 MT CO₂e annually.
• Electric power entities. Any entity importing or delivering electricity in New York State, or any entity with greenhouse gas emissions from electricity generation.
• Agricultural lime and fertiliser suppliers. Any supplier of agricultural lime or nitrogen-based fertilisers in New York State at any quantity.
• Anaerobic digestion facilities. Any facility receiving wastes capable of generating 10,000 or more MT CO₂e annually.

The key threshold for most industrial facilities is 10,000 MT CO₂e annually. For fuel and materials suppliers, the threshold is zero — any supply quantity triggers a reporting obligation. Organisations that supply fuel or materials into New York markets should confirm their obligations regardless of how much they supply.

What must be reported

Covered entities must report the following in their annual GHG report:

• Total GHG emissions by gas type (CO₂, CH₄, N₂O, and fluorinated gases where applicable), converted to CO₂-equivalent using 20-year global warming potentials
• Emission source categories contributing to total emissions
• Calculation methodologies applied for each source category
• Monitoring documentation — the methods used to measure or estimate activity data
• For large sources: third-party verification statements (see below)

New York's programme uses 20-year global warming potential (GWP) values rather than the 100-year GWPs more commonly used in corporate sustainability reporting and under California SB 253. Companies reporting to multiple programmes should pay careful attention to which GWP basis each requires, as the choice significantly affects reported totals for methane-intensive sectors.

Full compliance timeline

Deadline Obligation: September 1, 2026

Emissions Monitoring Plans (EMPs) submitted via NYS e-GGRT: December 31, 2026

GHG Monitoring Plans submitted: June 1, 2027

First annual emissions report (covering calendar year 2026): December 1, 2027

Third-party verification statements for large sources (covering 2026 data): August 10 annually (from 2028)

Verification statements for subsequent reporting years

The September 1, 2026 Emissions Monitoring Plan deadline is the most immediate obligation. An EMP documents how each covered entity will measure or estimate its GHG emissions — the monitoring methods, instrumentation, data quality procedures, and the responsible individuals. Submitting an EMP is a prerequisite to filing the annual report.

The NYS e-GGRT system is under active development. NYSDEC has committed to making the platform available before the September 2026 EMP deadline, but covered entities should monitor NYSDEC announcements for updates on system readiness and any changes to submission procedures.

Third-party verification requirements

The regulation distinguishes between covered entities based on emission volume when it comes to verification:

• Large sources: facilities or suppliers with annual emissions above a defined threshold must submit third-party verification statements alongside their annual report. Verification is due December 1 of the year following the reporting year (so December 1, 2027 for the first 2026 report), then August 10 annually thereafter.
• Other covered entities: below the large-source threshold must submit annual reports but are not required to include independent verification for the initial reporting years.

NYSDEC has indicated it will publish guidance on the specific thresholds that trigger verification requirements. Facilities near the boundary should plan for verification as a precaution until the threshold is clarified.

Penalties for non-compliance

The Climate Leadership and Community Protection Act authorises civil penalties for failure to report or for submitting inaccurate reports. Under New York's Environmental Conservation Law, penalties for regulatory violations can reach $37,500 per day per violation. NYSDEC has indicated that it will publish enforcement guidance specific to the reporting programme, but covered entities should treat the reporting obligations as binding from the September 2026 EMP deadline.

How New York's programme differs from California SB 253

Both New York and California now have mandatory GHG reporting requirements, but they operate at different levels and with different purposes:

Feature

• New York (6 NYCRR Part 253)
• California SB 253

Level

• New York (6 NYCRR Part 253): Facility/entity-level reporting
• California SB 253: Corporate-level consolidated reporting

Revenue threshold

• New York (6 NYCRR Part 253): None — threshold is emissions volume (10,000 MT CO₂e)
• California SB 253: $1 billion annual revenue

Scopes covered

• New York (6 NYCRR Part 253): Direct emissions from NY operations
• California SB 253: Scope 1 and 2 globally (Scope 3 future)

GWP basis

• New York (6 NYCRR Part 253): 20-year GWPs
• California SB 253: 100-year GWPs (GHG Protocol)

First report due

• New York (6 NYCRR Part 253): June 1, 2027
• California SB 253: August 10, 2026

Assurance/verification

• New York (6 NYCRR Part 253): Third-party verification for large sources
• California SB 253: Limited assurance from 2027 reporting cycle

Companies with operations in both states may find that data collected for one programme partially satisfies the other — but methodology alignment is not automatic. The GWP basis difference alone means the same physical emissions will produce different reported numbers under each programme.

What covered entities should do now

• Confirm coverage. Review the entity categories against your New York operations, supply arrangements, and emission volumes. The scope is wider than many facilities expect — fuel and material suppliers have no volume threshold.
• Establish your baseline emission inventory. Begin gathering 2025 or 2026 activity data now to have a baseline for your EMP. The monitoring plan must reflect actual or planned measurement methods — you cannot write it without knowing your sources.
• Map your emission sources. Identify every source category relevant to your operations: combustion equipment, process emissions, fugitive emissions. Match each to the appropriate calculation methodology.
• Prepare for the NYS e-GGRT system. Register your organisation in the system as soon as it becomes available. Systems that require data migration from other platforms often reveal data gaps — better to find them six months before the deadline than six days before.
• Assess verification obligations. If your emissions are near or above the large-source threshold, engage a third-party verification provider early. As with GHG assurance under SB 253, early engagement reduces cost and gives time to address data quality issues before submission.

For companies subject to multiple state reporting requirements, see our overview of US state corporate GHG disclosure requirements.