Executive Summary
Climate regulation is progressing in New York State with finalization of its Mandatory Greenhouse Gas Reporting Program. This new rule reflects a broader shift toward enforceable, data-driven climate policy grounded in standardized emissions information.
This program establishes a reporting program designed to provide data that regulators need to design, implement, and enforce future climate measures under the Climate Leadership and Community Protection Act. For companies operating in or supplying into New York, Part 253 introduces a clear compliance baseline that demands rigor in emissions measurement, governance, and documentation well before any pricing or reduction mechanisms take effect.
For obligated entities, this program serves as a test of organizational readiness. Mandatory reporting regimes such as Part 253 may expose weaknesses in data systems, internal controls, and accountability that voluntary disclosures often mask. However, entities that respond proactively by strengthening methodologies, governance, and systems, will be far better positioned as climate regulation continues to mature.
Who
Issuing Authority:
On December 1, 2025, the New York State Department of Environmental Conservation (DEC) finalized the Mandatory GHG Reporting Program under 6 NYCRR Part 253.
Obligated Entities:
Under the program, entities with significant greenhouse gas (GHG) emissions and operating in New York State must report emissions monitoring plans and emissions figures annually. These entities include:
- Owners/operators of facilities emitting at least 10,000 metric tons of CO2eannually (e.g., industrial operations, landfills, waste-to-energy facilities).
- Fuel suppliers delivering any natural gas, liquid fuels, CNG/LNG, coal, and petroleum products to end users in New York State.
- Waste haulers and transporters whose transported waste generates at least 10,000 metric tons of CO2e annually, including out of state.
- Electric power entities, including those importing any energy or emitting any GHG in the state.
- Agricultural lime and fertilizer suppliers emitting at least 10,000 metric tons of CO2e annually.
- Certain waste processing facilities (e.g., anaerobic digestion, wastewater) whose imported wastes generate at least 10,000 metric tons of CO2e annually.
Entities Requiring Verification:
Large Emission Sources will also require third-party verification by DEC-accredited verifiers. These include:
- Owners/operators of facilities emitting at least 25,000 metric tons of CO2e.
- Fuel suppliers delivering at least 15 million cubic feet of natural gas, CNG, or LNG; 100,000 gallons of liquid fuels or petroleum products; or 500 short tons of coal to end users in New York annually.
- Waste haulers and transporters whose transported waste generates at least 25,000 metric tons of CO2e annually, including out of state.
What
The rule establishes a mandatory GHG emissions reporting regime to collect data on sources of climate pollution across New York. The regime does not impose direct emissions reduction mandates or cap-and-trade compliance by itself. Key reporting requirements include:
- Measurement and calculation of annual GHG emissions in metric tons of CO2e.
- Submission through DEC’s online reporting platform (NYS e-GGRT) once available.
- Maintenance of a GHG Monitoring Plan detailing how emissions are quantified and verified.
Where
The rule applies to entities located or operating in New York State, including in-state facilities and suppliers whose products are used in New York (e.g., fuels). For waste haulers and transporters, waste transported out of state can trigger reporting if associated emissions exceed thresholds.
In-scope entities will need to report emissions via the New York State Greenhouse Gas Reporting Tool (NYS e-GGRT) every year. While the NYS e-GGRT electronic reporting platform is currently being developed, it is expected to be similar to the federal U.S. EPA e-GGRT system.
When
The rule was finalized on December 1, 2025 and becomes effective after publication in the State Register.
Entities that operate anaerobic digesters, handle liquid wastes, or are solid waste management facilities and are subject to the program’s reporting requirements must submit a separate Emissions Monitoring and Measurement Plan (EMMP) addressing methane emissions to the DEC for approval by September 1, 2026. Large Emission Source reporting entities must also report GHG Monitoring Plans to the DEC by December 31, 2026.
For the first year of GHG emissions reporting, entities must report 2026 emissions with an initial submission deadline of June 1, 2027, and annual updates thereafter. Verification deadlines will be extended in the early years to provide compliance flexibility, with the first verification reports for 2026 emissions due December 1, 2027.
Uniqus POV
Why
New York’s Mandatory GHG Reporting Program will close an important data gap in the State’s climate governance. While New York has some of the most ambitious statutory climate targets in the country under the Climate Leadership and Community Protection Act (CLCPA), policymakers have lacked consistent, economy-wide data on where emissions are generated, by whom, and in what quantities. Part 253 establishes a standardized, auditable emissions baseline across major emitting sectors, creating the foundation needed to design, implement, and enforce future climate policies.
How Uniqus Can Help
Companies anticipating or subject to the NYS GHG Reporting Program will face complex data, systems, compliance, and governance challenges. By operationalizing NYS GHG reporting obligations efficiently and accurately, Uniqus helps clients reduce regulatory risk while positioning their sustainability programs for future regulatory and investor expectations. Uniqus Consultech offers tailored support across core areas:
