The federal government may be delaying greenhouse gas (GHG) emissions oversight, but New York isn't waiting around.
In December 2025, the New York State Department of Environmental Conservation (NYSDEC) finalized Mandatory GHG Reporting Program regulations (6 New York Codes, Rules and Regulations [NYCRR] Part 253), establishing a statewide requirement for emissions data collection across a wide range of sectors.
The tracking period is already underway (as of January 1, 2026), and organizations have until 2027 to submit first reports.
What’s changed?
Under Part 253, NYSDEC will require covered reporting entities to quantify and annually report GHG emissions and related activity data. The program is a data collection requirement only and does not impose emission limits or reduction targets. However, the information collected will be used to support New York’s broader climate policy objectives under the Climate Leadership and Community Protection Act (Climate Act).
Who’s required to report?
The regulation applies to a broad set of entities, including both emitters and suppliers. Organizations may be subject to reporting even if they do not operate large facilities in New York. Reporting is required for:
- Facilities in New York emitting 10,000 metric tons of carbon dioxide equivalent (CO₂e) or more annually.
- Fossil fuel suppliers (gas, petroleum products, and coal) who serve New York end users (with no minimum quantity threshold).
- Waste haulers and transporters exceeding 10,000 metric tons CO₂e.
- Electric power entities, including importers, exporters, and retail providers.
- Suppliers of agricultural lime and fertilizer.
- Anaerobic digesters and certain liquid waste storage operations that would generate 10,000 or more metric tons of CO₂e per year.
Some entities categorized as large emission sources will also be required to obtain third party verification of their emissions data using NYSDEC accredited verification bodies.
New York’s Part 253 dates and deadlines
Organizations should be aware of the following milestones:
- January 1, 2026: Emissions tracking period begins.
- June 1, 2027: First emissions reports due to NYSDEC.
- December 1, 2027: Verification statements due for entities subject to verification requirements.
Reports must be submitted annually thereafter.
How this compares to federal programs
If you’re familiar with the US Environmental Protection Agency’s (EPA) GHG Reporting Program (GHGRP), New York’s Part 253 won’t feel new. Regulatory burdens on entities required to report are expected to be minimized by using and accepting data already reported under existing state and federal requirements, such as the Regional GHG Initiative (RGGI) and the EPA’s GHGRP (Part 98).
The biggest technical difference is New York’s use of 20-year global warming potential (GWP) instead of the standard 100-year metric. This change dramatically increases the “weight” of short-lived climate pollutants:
- Methane: Under the 20-year metric, methane is weighted roughly 84 times more than CO₂.
- Federal standard: Under the 100-year metric used by the EPA, that same methane is only weighted about 28 times more than CO₂e.
For methane-heavy operations such as waste management, natural gas distribution, or agriculture, this means New York emission figures will appear significantly higher than federal filings. It’s important to call out this difference to ensure consistent environmental, social, and governance (ESG) reporting for your stakeholders.
The second major shift: New York mandates third-party verification for large sources, replacing the EPA's self-certification model. This adds an additional layer of credibility expected to be a minimal administrative cost for reporting entities.
What to do now
The tracking period has started. Here's where to focus:
- Assess whether you’re in scope to confirm whether operations or sales into New York trigger reporting requirements.
- Evaluate existing GHG inventories to determine whether current data-collection methods align with Part 253 requirements.
- Identify potential verification obligations and planning timelines accordingly.
- Monitor NYSDEC guidance as additional technical instructions are released.
New York’s Mandatory GHGRP reflects a broader trend toward state level emissions transparency and leadership, particularly as federal reporting requirements remain hesitant (read EPA Delays Greenhouse Gas Reporting: Now What?). For many organizations, this regulation may represent the first step toward more comprehensive future climate related obligations.
Meet our experts:
Desmond Zheng, MSSE, Consultant specializing in GHG reporting and Net Zero transition plans: Desmond brings his experience in sustainable engineering and renewable energy to support organizations of all size in developing GHG inventories to achieve Net Zero.
