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Navigating New York’s Mandatory GHG Reporting Program: What You Need to Know

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Navigating New York’s Mandatory GHG Reporting Program: What You Need to Know

New York is laying out the groundwork for addressing GHG emissions and climate change. In its most recent environmental initiatives, the New York State Department of Environmental Conservation (NYDEC) finalized the mandatory GHG reporting program 6 NYCRR Part 253 on December 1, 2025.

This data-collection initiative under the Climate Leadership and Community Protection Act requires major emitters to report their greenhouse gas emissions on an annual basis.

It would obligate subject industries, large facilities, and emission sources to monitor, report, and verify their greenhouse gas emissions and maintain records of specified supporting data. With information from 2026, they would have to turn in the first report by June 2027.

Statewide granular and auditable emissions data reporting will lead to informed and targeted GHG reduction measures.

What is the Mandatory GHG Reporting Program (6 NYCRR Part 253)?

The program directs a diverse array of entities, including fuel suppliers, transporters, electric power establishments, and large emission sources, to report their greenhouse emissions annually, as outlined in the Climate Action Council’s Scoping Plan.

This mandatory reporting to NYDEC will facilitate a more precise quantification of GHG emissions, yield data-driven insights into climate policies, and assist in evaluating GHG reduction compliance.

Any delays, omissions, or inaccuracies in submitting emission data reports, verification statements, or required documents are causes for violation. This puts pressure on concerned entities to accurately and reliably monitor and record their emissions.

Applicability & Threshold

Depending on the source and level of their emissions, specific facilities and entities would be required to monitor their greenhouse gas emissions under NYCRR Part 253. Here are the reporting entities and their applicability threshold:

>> Owners & Operators: New York-based facilities with 10,000 metric tons or more of CO₂e emissions per year.

>> Fuel Suppliers: Suppliers of natural gas, liquid fuels and petroleum products, liquefied natural gas and compressed natural gas & coal with any amount of GHG emission.

>>Waste haulers and transporters: An estimated 10,000 MT CO₂e are released annually from solid waste transported to landfills or combustion facilities outside of New York.

>> Electric power entities: The applicability threshold for electric power entities are any GHG emissions or imported MWh.

>> Agricultural lime and fertiliser suppliers: Any supplier licensed to distribute agricultural lime and fertiliser in NY, necessary to generate any GHG emissions per emission year

>> Anaerobic digestion and liquid storage of waste: If the facility generates 10,000 MT of CO₂e per year.

Entities below these thresholds generally are not required to report, but ongoing data or operational changes can trigger reporting obligations if emissions rise above the threshold.

Large emission sources

>> Owners and operators of facilities with 25,000 metric tons or more of CO₂e per year.

>> Natural gas suppliers with 15,000,000 cubic feet or more of natural gas per year.

>> Liquid fuel and petroleum products suppliers with 100,000 gallons or more of affected liquid fuels per emission year.

>> Liquefied natural gas and compressed natural gas with 15,000,000 cubic feet or more of liquefied natural gas and/or compressed natural gas per emission year.

>> Coal suppliers with 500 U.S. short tons of coal per emission year.

>> Waste haulers and transporters with 25,000 metric tons CO₂e per emission year.

What are the Reporting Requirements?

New York facilities classified as reporting entities or large emission sources must submit an audit-ready emissions report to NYDEC in accordance with EPA 40 CFR Part 98. Concerned entities must present an emissions data report no later than June 1 of the calendar year immediately following each emission year.

Typical reporting includes:

>> Total annual GHG emissions for covered gases (CO₂, methane, nitrous oxide, etc.)

>> Emissions from stationary combustion, fugitive sources, upstream emissions from fossil fuel production for fuel suppliers, and certain out-of-state emissions tied to New York operations.

Large emission sources must obtain third-party verification services for their reports from a verification body that meets the specified standards. Verification statements must be submitted annually or on a multi-year schedule as specified by the authorities.

Reporting Mechanism

The NYS e-GGRT or any other reporting tool authorised by the department must be used by reporting entities to submit emissions data reports and any revisions. This ensures accurate transmittal and receipt of necessary GHG data.

Why does Mandatory GHG Reporting Program matter?

NYCRR Part 253 is a strategic climate action for collecting entity-level emissions data. It will allow authorities to improve the accuracy of their annual Statewide GHG Emissions Report and climate inventories.

This long-term initiative will support targeted climate policies and investment decisions aimed at lowering emissions and improving air quality.

Similar to California’s Mandatory GHG Reporting Regulation (MRR), this reporting can support planning for future programs (e.g., potential cap-and-invest systems) informed by robust emissions data.

Precise GHG monitoring and reporting also have community and policy implications. Better data support air quality planning and environmental justice insights. It helps maintain accurate state emissions tracking.

How to Begin Your GHG Reporting Journey?

New York’s Mandatory GHG Reporting Program encourages facilities to take proactive steps to handle greenhouse gas emissions. However, complex operations and disjointed systems can make establishing monitoring systems challenging.

They might have trouble meeting verification requirements, such as third-party audits for large emitters, and gathering standardised data from various sources.

High compliance costs, inconsistent emissions data, and penalties add pressure, especially for carbon-intensive sectors. First reports are due by June 2027,
ESG solutions, such as SAMESG, can offer a one-stop solution for collecting and disclosing GHG emissions.

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Automate Data Consolidation: SAMESG streamlines data collection and collates greenhouse gas emission data from multiple sources with ease.

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Summary – What You Need to Know

Element: New York Mandatory GHG Reporting (Part 253)

Purpose: Annual emissions data collection to inform climate policy

Who Must Report: Large emitters, fuel suppliers, electric entities, waste haulers, etc.

Reporting Metric: CO₂e with 20-year GWP

Verification: Required for larger sources via third-party verifiers

First Report Due: June 1, 2027 (for 2026 emissions)

Penalties: Focus on compliance; not tied to emissions limits or cap-and-trade

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Rajagopal Kannan

Director – Projects & Value Chain at SAM Corporate LLC

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Rajagopal Kannan is the Director of Projects & Value Chain at SAM Corporate LLC, leading ESG, risk management, and sustainability initiatives. With over 20 years of experience, including a decade in banking and financial risk, he specializes in credit structuring, Basel II & III, ISO 31000, COSO ERM, internal audit, and regulatory compliance under CBUAE, DFSA, ADGM, and SCA.

His current focus lies in ESG integration, climate and sustainability risk management, and value chain sustainability. A GRI-certified Sustainability Professional and GARP-certified SCR holder, he also holds multiple global credentials including PRM®, GRCP, GRCA, CRCMP, CBiiiPro, CSM, and CISI Level 3.

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