New York Finalizes Mandatory GHG Reporting Rule: Who Must Report and What’s Due in 2026–2027

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The New York State Department of Environmental Conservation (NYSDEC) has adopted final regulations establishing a Mandatory Greenhouse Gas (GHG) Reporting Program pursuant to the Climate Leadership and Community Protection Act (Climate Act). The regulations, codified at 6 NYCRR Part 253: Mandatory Greenhouse Gas Reporting (Part 253), became effective on December 25, 2025, and establish statewide requirements for monitoring and reporting GHG emissions.

The data collected under Part 253 will support implementation of the Climate Act by strengthening New York’s annual statewide GHG emissions inventory, informing climate policy decisions, assessing compliance with emissions-reduction programs, and tracking progress toward the Climate Act’s GHG reduction targets.

Who must report under Part 253?

Part 253 requires certain entities to monitor and report GHG emissions, including:

  • Owners and operators of facilities located in New York State that emit 10,000 metric tons or more of carbon dioxide equivalent (CO₂e) per reporting year, as determined in accordance with Part 253 definitions and calculation methodologies.

  • Fuel suppliers that supply covered fuels for end use in New York State, including suppliers of natural gas, liquid fuels, petroleum products, liquefied natural gas (LNG), compressed natural gas (CNG), and coal.

  • Waste haulers and transporters (exporters) that transport solid waste generated in New York to landfills or combustion facilities outside of New York, where the estimated GHG emissions associated with that waste equal or exceed 10,000 metric tons of CO₂e per reporting year.

  • Electric power entities, including electricity generators, importers, exporters, and load-serving entities, that generate electricity associated with GHG emissions or import megawatt-hours (MWh) of electricity into New York State.

  • Suppliers of agricultural lime and fertilizer that supply covered products for use in New York State, as defined in Part 253.

  • Anaerobic digestion and liquid waste storage operations, including wastewater treatment plants and concentrated animal feeding operations, where imported or generated waste results in estimated GHG emissions of 10,000 metric tons or more of CO₂e per reporting year.

What emissions and data must be reported?

Entities subject to Part 253 must monitor, quantify, and annually report GHG emissions and associated information in accordance with the definitions, calculation methodologies, and reporting procedures set forth in the regulation.

Part 253 reporting requirements include the following, as applicable:

NY Part 253 Reporting Requirements

Reporting Requirement

Details

Annual GHG Emissions

Total annual emissions of CO₂, CH₄, N₂O, and other covered GHG, expressed in metric tons of CO₂e, calculated in accordance with Part 253.

Emissions by Source Category

Emissions data reported by applicable source type, including stationary combustion and process emissions, waste-related emissions, electricity generation or imports, fuel supply activities, and other covered source categories.

Facility and Activity Data

Operational data used to calculate emissions, including fuel usage, production or throughput data, waste quantities, electricity generation or imports, and other activity metrics required under Part 253.

Fuel Supply Data

For fuel suppliers, the quantity and type of covered fuels supplied for end use in New York State during the reporting year.

Waste Management Data

For waste transporters/exporters and anaerobic digestion or liquid waste storage operations, quantities of waste managed or transported and associated emissions calculations.

Electric Power Data

For electric power entities, megawatt-hours (MWh) generated, imported, exported, or delivered in New York State, as applicable.

Agricultural Lime and Fertilizer Supply Data

For suppliers of agricultural lime and fertilizer, quantities supplied for use in New York State and associated emissions calculations.

Emissions Monitoring and Measurement Plan (EMMP)

Submission of an EMMP describing monitoring/measurement methodologies, data collection systems, calculation approaches, quality assurance procedures, and recordkeeping practices, as required.

Large Emission Sources GHG Monitoring Plan

Submission of a GHG Monitoring Plan describing responsible personnel; data collection and calculation methodologies; quality assurance/quality control (QA/QC) and monitoring equipment maintenance procedures; and documentation practices necessary to remain current and audit-ready.

Third-party Verification Documentation (Large Emissions Sources only)

Entities designated as Large Emissions Sources must obtain and submit independent third-party verification of reported emissions in accordance with Part 253.

Is verification of emissions data required?

Yes, for “Large Emission Sources.” Part 253 requires third-party verification annually for Large Emissions Sources. Verification must be conducted by a NYSDEC-accredited verification body and submitted to the NYSDEC in accordance with applicable deadlines.

Large Emissions Source thresholds include:

  • Facilities that emit 25,000 metric tons or more of CO₂e per emission year.

  • Suppliers of natural gas that deliver 15,000,000 cubic feet or more of natural gas per emission year.

  • Suppliers of liquid fuels and petroleum products that deliver 100,000 gallons or more of affected liquid fuels per emission year.

  • Suppliers of LNG and CNG: that deliver 15,000,000 cubic feet or more of LNG and/or CNG per emission year.

  • Suppliers of coal that deliver 500 U.S. short tons of coal per emission year.

  • Waste haulers and transporters (exporters) for which the sum of emissions associated with waste transported to out-of-state landfill and combustion facilities equals or exceeds 25,000 metric tons of CO₂e per emission year.

When are the key reporting deadlines?

Initial Implementation Deadlines

  • September 1, 2026 – Emissions Monitoring and Measurement Plans due for applicable reporters under Sections 2.2 and 2.13.

  • December 31, 2026 – Large Emissions Source GHG Monitoring Plans due to the Department.

  • June 1, 2027 – First Emissions Data Report due to the Department for emissions year 2026.

Large Emissions Source Verification Deadlines

Verification statements are due for the previous emissions year and must be submitted by the following dates:

  • December 1, 2027 – Verification statements due for emissions year 2026.

  • December 1, 2028 – Verification statements due for emissions year 2027.

  • August 10 (beginning in 2029) – Permanent annual deadline for verification statements.

Part 253 will require reporting entities to submit reports via the NY State Electronic Greenhouse Gas Emissions Reporting Tool (NYS e-GGRT), an electronic reporting platform currently being developed by the NYSDEC. 

What are the penalties for non-compliance?

Part 253 has very strong enforcement implications. Any violation of Part 253 can result in a penalty under Article 71 of the New York Environmental Conservation Law. A company may incur daily penalties for any violation. It also provides NYSDEC full inspection authority and may pursue enforcement under the same law.

On the reporting side, each day or part of a day that a required report remains unsubmitted, late, incomplete, or inaccurate is a separate violation. The definition of report includes: Emissions data reports, verification statements, and any other required submission.

Additionally, the following are considered separate violations under Part 253:

  • Each metric ton of CO₂e emitted

  • Each failure to measure, collect, record, or preserve information in the manner unless it’s demonstrated that the data gap was due to maintenance or calibration required by Part 253

What should companies do to prepare now?

Companies that may be subject to Part 253 should consider taking the following steps:

  1. Determine Applicability

    Assess whether your operations meet the reporting thresholds under Part 253. This may require developing or refining a GHG inventory aligned with Part 253 definitions and calculation methodologies to evaluate emissions and activity-based applicability. For example, Part 253 requires the use of 20-year global warming potentials (GWP-20), which differs from the 100-year GWP approach commonly used under other federal and voluntary reporting programs. This could cause methane-heavy sectors such as oil and gas, waste, and fuel suppliers to have materially higher CO₂e totals under the Part 253 methodology.

  2. Evaluate Large Emissions Source Thresholds

    Determine whether your entity meets the Large Emissions Source thresholds that trigger annual third-party verification requirements.

  3. Fulfill Monitoring and Planning Requirements

    If subject to the EMMP or Large Emissions Source GHG Monitoring Plan requirements, develop and document monitoring methodologies, data collection systems, internal controls, and quality assurance procedures. Submit plans to NYDEC by the applicable deadlines.

  4. Integrate Part 253 Requirements into Existing Framework

    Establish and incorporate the requirements of Part 253 into an emissions accounting framework to ensure the accurate generation of required reports. Emissions calculations, emission factors, and data management systems must be aligned with and consistent with Part 253 methodologies and documentation requirements. If subject to third-party verification, reporting entities should also ensure that data systems and controls are designed to support auditability and independent review.

  5. Start Tracking Data Early

    Calendar year 2026 is the first emissions year subject to reporting. Entities should begin tracking required data early to ensure readiness for the first emissions report due June 1, 2027. Large Emissions Sources should identify and engage a NYDEC-accredited third-party verifier in advance of the December 1, 2027, verification deadline. Organizations with experience in GHG inventory development and verification under similar programs (such as CARB’s Mandatory Reporting Regulation) are well-positioned to adapt existing systems to meet Part 253 requirements. 

Ready to get started?

KERAMIDA is an experienced CARB-Accredited Verification Body and is positioned to become an NYSDEC-Accredited Verification Body. Our team of GHG reporting and verification experts can help you with all aspects of the Part 253 reporting compliance, including GHG emissions inventory development, Emissions Monitoring and Measurement Plan development, Large Emission Source’s GHG Monitoring Plan development, pre-verification of GHG emissions, and reasonable verification for large emitters.

Contact us or call (800) 508-8034 to speak with one of our Part 253 reporting experts to get started.

Authors

Xuqing Xiong, PE, MS
Vice President, GHG & Sustainability Data
KERAMIDA Inc.

Contact Xuqing at xxiong@keramida.com

Kindal Keen
Manager, GHG & Sustainability Data
KERAMIDA Inc.

Contact Kindal at kkeen@keramida.com

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