Businesses must navigate an increasingly complex and evolving regulatory landscape for sustainability reporting, and recent greenhouse gas reporting rules in New York state add another facet to that landscape. These rules will likely have an outsized impact on manufacturers and other industrial companies, given their higher emissions output compared to many other industries.

Effectively collecting, processing and analyzing emissions data is essential for regulatory compliance, while also giving businesses the ability to make informed strategic decisions. For companies doing business in New York, understanding current regulatory obligations and requirements, as well as those on the horizon, is critical.

Background and who is affected

Effective Dec. 1, 2025, the New York State Department of Environmental Conservation (DEC) adopted the Mandatory Greenhouse Gas Reporting Program (Part 253) as recommended by the Climate Action Council Scoping Plan. The reporting program requires certain reporting entities to annually report emissions and related data to the DEC.

Those affected include:

Owners and operators of facilities that produce 10,000 metric tons or more of carbon dioxide equivalent per year
Suppliers of natural gas to end users in New York state
Suppliers of liquid fuels and petroleum products to end users in New York state
Suppliers of compressed natural gas and liquefied natural gas to end users in New York state
Suppliers of coal to end users in New York state
Waste haulers and transporters if emissions from solid waste transported to landfills or combustion facilities outside of New York state exceeded 10,000 metric tons of carbon dioxide equivalent emissions in any year
Electric power entities
Owners and operators of anaerobic digestion and liquid waste storage if wastes imported to the facility or generated at the facility are in an amount that would generate 10,000 metric tons of carbon dioxide equivalent emissions in the reporting year

For those affected, emissions monitoring and measurement plans are due Sept. 1, 2026. The first emissions data reports are due to the DEC on June 1, 2027, for the year ended Dec. 31, 2026.

Certain entities that qualify as large emission sources are required to submit verification statements through a verification body accredited by the DEC. Those who qualify as large emission sources are required to submit a greenhouse gas monitoring plan by Dec. 31, 2026, as well as verification statements by Dec. 1, 2027, for the year ended Dec. 31, 2026. Those defined as large emission sources include:

Owners and operators of facilities that meet or exceed 25,000 metric tons or more of carbon dioxide equivalent per emission year
Suppliers of natural gas to end users in New York state that exceed 15 million cubic feet or more of natural gas per emission year
Suppliers of liquid fuels and petroleum products to end users in New York state that exceed 100,000 gallons or more of liquid fuels or petroleum products per emission year
Suppliers of compressed natural gas and liquefied natural gas to end users in New York state that exceed 15 million cubic feet or more of compressed and/or liquefied natural gas per emission year
Suppliers of coal to end users in New York state that exceed 500 U.S. short tons of coal per emission year
Waste haulers and transporters if emissions from solid waste transported to landfills or combustion facilities outside of New York state exceeded 25,000 metric tons of carbon dioxide equivalent emissions per emission year