Introduction

New York State has finalized a Mandatory Greenhouse Gas Reporting Program (Reporting Program or Part 253) that will significantly expand emissions reporting requirements across the state. The program applies to major emitters across sectors including waste, energy, fuel supply, and industrial operations. The goal is to improve statewide emissions transparency and equip policymakers with accurate data that supports long term climate planning.

What the Mandatory Greenhouse Gas Reporting Program Does

The Reporting Program is designed to collect comprehensive data on greenhouse gas emissions from a wide range of sources. It supports the state’s Climate Leadership and Community Protection Act by creating a consistent approach to emission tracking. The program focuses on reporting and data collection. It does not require direct emissions reductions at this stage. It is expected that the program will inform future climate policies and regulation.

Who Must Comply

The program covers multiple types of entities. Below is an overview of the major categories.

Facilities That Emit 10000 MT CO2e or More: These include electricity generation facilities, industrial operations, waste to energy plants, landfills, natural gas compressor stations, and other large stationary sources.

Fuel Suppliers: Suppliers of natural gas, liquid fuels, coal, and other petroleum products delivered to end users in New York must report the greenhouse gas emissions associated with their supplied fuels.

Electricity Importers and Power Entities: Entities that import electricity into New York or generate electricity within the state must report emissions related to their activities.

Waste Transporters and Haulers: If the emissions associated with transported waste exceed 10000 MT CO2e per year, the transporter must report. This applies even when waste is sent to facilities outside New York.

Waste Management and Treatment Facilities: Anaerobic digesters, wastewater treatment operations, and other waste handling or storage sites that produce 10000 MT CO2e or more must report.

Agricultural Product Suppliers: Suppliers of agricultural lime or fertilizers must report emissions attributable to their products when they are used in New York.

What Must Be Reported

Entities must report annual greenhouse gas emissions in CO2e using approved calculation methodologies. This includes combustion emissions, process emissions, fugitive emissions, waste related emissions, and other specified categories. Data must be supported by accurate records including fuel use, product supply volumes, electricity imports, and waste handling information.

Large emission sources may be required to prepare a monitoring plan to describe how emissions data will be collected and managed. These sources may also require third party verification of their reported emissions beginning with the first reporting cycle.

Key Deadlines

The first reporting year is 2026.

Reports for 2026 emissions are due by June 1, 2027.

Large emission sources must submit their monitoring plan by December 31, 2026.

If verification is required, verified emissions reports must be submitted by dates specified by the Department of Environmental Conservation for each reporting cycle.

Tools and Support

New York State will provide an online reporting platform called the NYS e-GGRT. The state also offers a greenhouse gas estimation tool to help entities determine whether their emissions exceed reporting thresholds. Guidance documents and training resources will be released as implementation moves forward.

What the Program Does Not Do

The Reporting Program does not impose emissions limits or reduction obligations at this time. Reporting does not require the purchase of allowances or credits. The purpose is to establish a consistent and reliable emissions data foundation that supports policy development.

Why This Matters for Companies

Businesses that fall under the program should begin preparing early. Accurate data collection systems, internal controls, and record keeping procedures will be necessary. Entities that prepare now will reduce compliance risks and position themselves for potential future regulatory changes.

Investors, regulators, and communities will gain better visibility into emissions profiles across sectors. This shift toward greater transparency may influence investment decisions and operational planning.

Next Steps for Affected Organizations

• Conduct an internal review to estimate annual greenhouse gas emissions.
• Determine whether your organization or suppliers meet reporting criteria.
• Establish a clear process to collect and retain emissions data.
• Track updates from the Department of Environmental Conservation regarding reporting tools and guidance.
• Develop a monitoring plan if required based on your emissions profile.

Conclusion

New York’s Mandatory Greenhouse Gas Reporting Program represents a major expansion of emissions transparency. Although it does not mandate reductions, it provides a critical data framework for future climate action in the state. Organizations should begin preparing now to ensure accurate reporting and to stay ahead of evolving regulatory expectations.

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