December saw the New York State Department of Environmental Conservation (DEC) finalize regulations establishing the state’s Mandatory Greenhouse Gas Reporting Program under Part 253 of the environmental code. This program will require specified entities to annually measure and report greenhouse gas (GHG) emissions and related data to DEC, with the first reports covering emissions from calendar year 2026 due by June 1, 2027. The program is a core component of implementing the state’s Climate Leadership and Community Protection Act (Climate Act), a landmark statute aimed at reducing emissions across the economy.
For professionals in the corporate governance and compliance space, New York’s mandatory reporting regime represents a transformative regulatory development that will have broad implications on environmental disclosure, risk oversight and operational transparency. Corporations with operations in New York must now integrate climate data collection and reporting into governance frameworks in ways that were previously the preserve of voluntary or federal reporting programs.
At its core, the Mandatory GHG Reporting Program is a data-collection-only regulation. It does not impose direct limits on emissions or require companies to obtain emission allowances. Instead, it establishes a comprehensive system for quantifying emissions so DEC and the public have accurate, state-specific data to inform future climate policy and monitor progress toward statutory emissions reduction targets.
Scope and requirementsUnder the new rules, a diverse set of actors will be subject to reporting obligations. Owners and operators of facilities that emit 10,000 metric tons or more of carbon dioxide equivalent (CO₂e) annually must report. Fuel suppliers (including natural gas, liquid fuels, compressed and liquified natural gas, and coal) that deliver any amount of fuel to end users in New York are required to report. Electric power entities that emit any GHG or import megawatt hours of electricity must report. Waste haulers and transporters exporting waste that will generate more than 10,000 metric tons of CO₂e per year are included, as are suppliers of agricultural lime and fertilizer that generate GHG emissions and operators of anaerobic digestion or liquid waste storage facilities meeting the same emission threshold.
Reporting entities will use an online platform developed by DEC called the New York State Greenhouse Gas Reporting Tool (NYS e-GGRT) to submit data annually. Reporting must include emissions from stationary combustion, process and fugitive sources, upstream out-of-state emissions linked to fuel use and, where applicable, detailed activity or product data for certain industrial sectors.
Entities exceeding higher thresholds – for example, facilities with emissions of 25,000 metric tons CO₂e or more, or fuel suppliers exceeding specified volume thresholds – are classified as large emission sources and must obtain third-party verification of their emissions data. This will require engaging accredited verifiers and preparing greenhouse-gas monitoring plans for review by DEC.
Governance implications For boards, audit committees and corporate compliance functions, the GHG reporting program elevates climate governance from a strategic or voluntary reporting issue to a statutory compliance requirement. Organizations now face a regulatory obligation to establish robust systems for measuring, verifying and reporting emissions data. This drives a need for enhanced internal controls over environmental data and a rethinking of risk management frameworks to explicitly integrate climate-related risks and compliance responsibilities.
Governance professionals must ensure that companies have appropriate oversight and accountability structures to manage these new obligations. That includes ensuring that management teams have the expertise, resources and processes to collect accurate emissions data, address data gaps and respond to evolving regulatory definitions. Internal audit functions may need to expand their scope to include regular reviews of GHG data collection and reporting processes. Boards will need visibility into compliance readiness and any material risks associated with misreporting or non-compliance. External counsel, compliance officers and sustainability leads will likely play a more central role in advising on regulatory developments and assurance.
Operational readiness Professionals in ESG and sustainability roles should prioritize early assessments of organizational readiness, including gap analyses relative to the state’s detailed reporting requirements. Data infrastructure, personnel roles and responsibilities and quality assurance measures must be defined well before the first reporting deadline. For large emission sources, establishing relationships with third-party verifiers and developing thorough monitoring plans will be essential. Those planning for verification cycles must align internal timelines with DEC’s verification deadlines, which are staggered over the first few years of reporting.
The new reporting requirements also intersect with broader disclosure landscapes. Companies subject to SEC climate disclosure proposals or EU-based reporting obligations may find synergies in data collection and metric standardization. However, New York’s program is distinct in its regulatory foundation and specific thresholds, meaning compliance teams must ensure that their state-level reporting obligations are met independently of other frameworks.