New York's Mandatory Greenhouse Gas Reporting Program is officially here.
Starting June 2027, thousands of owners and operators of facilities, fuel suppliers, and waste transporters will need to submit detailed emissions data to the state, creating one of the most comprehensive climate reporting frameworks in the United States.
If your operations touch New York in any way, this regulation could apply to you. Here's what you need to know.
💡 See the full Enterprise guide to ESG reporting requirements in 2026.
What is New York's Mandatory Greenhouse Gas Reporting Program?
The New York State Department of Environmental Conservation finalized its reporting regulations on December 1, 2025, establishing a mandatory registry for tracking greenhouse gas emissions across the state's economy.
The program stems from the Climate Leadership and Community Protection Act (CLCPA) passed in 2019, which set ambitious emissions reduction targets for New York under Part 253.
The state’s long-awaited reduction mandates are here, and this reporting framework provides the foundation for future climate policy by establishing a reliable emissions dataset.
First reports covering 2026 emissions are, as of now, due June 1, 2027.
Who needs to report to New York’s Mandatory Greenhouse Gas Reporting Program?
The reporting requirements cast a wide net, covering entities that emit or supply products generating 10,000 metric tons of CO2 equivalents or more annually. This includes:
Who needs to report to New York’s Mandatory Greenhouse Gas Reporting Program?
The reporting requirements cast a wide net, covering entities that emit or supply products generating 10,000 metric tons of CO2 equivalents or more annually. This includes:
The regulation's reach extends beyond state borders—if you're supplying fuel, electricity, or transporting waste that ends up in New York, you may have reporting obligations.
What data must be reported to New York’s mandatory GHG reporting?
Reporting entities must submit annual emissions data through a web-based platform (similar to the federal e-GGRT system). Requirements include:
- Total annual GHG emissions in CO2 equivalent
- Emissions by source (combustion, industrial processes, waste, transport)
- Activity data and calculation methodologies
- Upstream emissions from fossil fuel extraction, production, and transmission
This last requirement is significant: New York wants visibility into the full lifecycle emissions of fuels and electricity consumed in the state, not just direct operational emissions, even if the source of energy comes from outside of the state.
Verification requirements
"Large Emission Sources" must verify their data through DEC-accredited third-party verifiers:
- Facilities emitting over 25,000 metric tons CO2e annually
- Fuel suppliers exceeding specific volume thresholds
- Waste haulers transporting 25,000+ metric tons CO2e
A DEC-accredited third-party verifier is an independent organization approved by the New York State Department of Environmental Conservation to validate GHG emissions reports submitted under New York’s mandatory reporting rules.
The first verification requires a full assessment including site visits and data system reviews. Facilities receiving a clean verification can use streamlined processes for the next two years.
Why this will matter to companies in and beyond New York
While this is technically a data collection program — not an emissions reduction mandate — it has broader implications:
Federal uncertainty, state action
With the federal EPA proposing to end reporting for 46 source categories under its Greenhouse Gas Reporting Program, New York's framework ensures continued emissions transparency. Other states are watching closely.
Multi-framework compliance
The emissions data required for New York overlaps significantly with other reporting frameworks:
- California SB 253 (for companies with $1B+ revenue)
- CSRD (for EU operations)
- CDP questionnaires
Companies already tracking Scope 1, 2, and 3 emissions can leverage existing data management systems—but smaller organizations may need to build these capabilities from scratch.
Supply chain ripple effects
The regulation's reach into fuel suppliers, waste haulers, and transporters means supply chain partners will need robust emissions tracking. This could influence procurement decisions and supplier requirements across industries.
Foundation for future policy
While currently focused on reporting, this data will inform New York's developing "cap-and-invest" program and potential relief for emissions-intensive, trade-exposed industries. Early compliance positions companies favorably for whatever comes next.
Significant penalties for non-compliance with New York’s mandatory GHG reporting
New York isn't taking enforcement lightly. Each violation category compounds:
- Every day a report is late, incomplete, or inaccurate = separate violation
- Every metric ton unreported = separate violation
- Each failure to collect required data = separate violation
A facility submitting a report 30 days late with minor calculation errors could face penalties exceeding $500,000.
How to prepare for New York’s mandatory GHG reporting
For 2026 (this year):
- Determine if your operations meet reporting thresholds
- Develop or update your greenhouse gas monitoring plan
- Begin collecting emissions data using approved methodologies
- Source a comprehensive, AI-augmented solution to streamline relevant data
- Large Emission Sources must submit monitoring plans by December 31, 2026
For 2027:
- Submit first emissions data report by June 1
- Complete third-party verification if required (deadlines vary)
Streamlining multi-state reporting with California
Companies with operations in multiple states face increasing reporting complexity. New York joins California and Washington in establishing mandatory GHG disclosure, and more states are likely to follow.
California SB-253: Overlapping metrics you can reuse if you’re already preparing
- Fuel consumption by facility and fuel type (natural gas, diesel, gasoline, etc.) → drives Scope 1 and NY combustion emissions
- Purchased electricity by facility (kWh + supplier/region) → drives Scope 2 and NY electricity-related reporting
- Refrigerants/fugitive emissions logs → Scope 1 and NY source-category reporting
- Waste volumes and treatment method (landfill/incineration/etc.) → Scope 3 and NY waste categories (where applicable)
- Standardized emissions factors + calculation methodologies → reusable across both regimes
- Facility boundaries + roll-up mapping (site → business unit → corporate) → required to avoid rework across state vs. corporate reporting
- Audit trail + evidence packs (source docs, approvals, change logs) → supports SB-253 assurance readiness and NY verification expectations
Where SB-261 fits
SB-261 is a climate risk report, not a second emissions inventory. Use your NY + SB-253 emissions outputs to inform:
- Regulatory exposure and compliance risk
- Transition risk narratives and mitigation action
- governance and controls already built for emissions reporting
The key to managing this complexity is building flexible emissions management systems that can:
- Collect and standardize data across facilities and suppliers
- Map to multiple regulatory frameworks simultaneously
- Maintain audit trails and documentation
- Adapt as regulations evolve
Organizations that view this as purely a compliance burden may miss the strategic opportunity: establishing a robust emissions data infrastructure now prepares you for the inevitable expansion of climate reporting requirements nationwide.
Take the next steps for New York's Mandatory Greenhouse Gas Reporting Program with Pulsora
If you're unsure whether your organization falls under New York's reporting requirements, now is the time to assess your exposure. The regulation's applicability isn't always clear-cut, particularly for entities with indirect New York connections through fuel sales or waste transport.
For companies already tracking emissions, the challenge is ensuring your existing methodologies align with New York's specific requirements—particularly around upstream emissions reporting and verification protocols.
For those starting from scratch, engaging consultants or adopting sustainability and carbon management platforms can accelerate the process and reduce compliance risk as 2027 approaches.
Stay ahead of evolving climate disclosure requirements. Contact Pulsora to learn how our platform helps companies efficiently manage multi-framework GHG reporting across jurisdictions.
