New York GHG Reporting Requirements: What Companies Need to Know

New York’s mandatory greenhouse gas (GHG) reporting program is underway. With the first compliance deadline already passed, organizations subject to 6 NYCRR Part 253 should be focused on meeting remaining 2026 requirements and preparing the data, controls and documentation needed for their first annual emissions reports in 2027.

The New York State Department of Environmental Conservation (DEC) finalized Part 253 to establish a statewide system for collecting greenhouse gas (GHG) emissions data in support of the state’s Climate Leadership and Community Protection Act. The regulation requires covered entities to quantify and report emissions using defined thresholds, calculation methodologies and reporting procedures.

For organizations with operations in New York, Part 253 makes emissions reporting a regulatory compliance function rather than simply a voluntary sustainability exercise. Meeting the requirements will depend on reliable emissions data, clear internal responsibilities and processes that can withstand regulatory and, when applicable, third-party review.

Preparing for Part 253 Compliance

Many organizations already track energy use, calculate GHG emissions or publish sustainability disclosures. Those existing processes can provide a starting point for Part 253 compliance, but they may not satisfy New York’s specific requirements.

Covered organizations will need to apply regulator-defined emissions boundaries and calculation methodologies while maintaining complete, consistent and supportable data. Those with multiple facilities, systems or business units may also need to coordinate information from numerous sources and establish consistent processes for collecting and reviewing it.

Documentation will be particularly important for organizations subject to third-party verification. Even organizations that are not required to obtain verification should establish repeatable processes and appropriate controls to support the accuracy and completeness of their annual reporting.

Who is Required to Report

Part 253 applies to several categories of entities based on their emissions or activities. Reporting entities include:

• Facility owners and operators: Facilities that emit 10,000 metric tons (MT) or more of CO₂e annually, as well as CO₂ Budget Sources subject to Part 242
• Fuel suppliers: Suppliers of natural gas, liquid fuels and petroleum products, compressed natural gas and liquefied natural gas, and coal. Reporting generally applies when any quantity is supplied that generates GHG emissions.
• Waste haulers and transporters: Entities transporting solid waste to landfills or combustion facilities outside New York when estimated emissions from that waste exceed 10,000 MT CO₂e in a year
• Electric power entities: Entities with GHG emissions or that import electricity into New York
• Agricultural lime and fertilizer suppliers: Suppliers of quantities that generate GHG emissions
• Anaerobic digestion and liquid waste storage operations: Facilities where imported or generated waste can produce 10,000 MT CO₂e in a reporting year

Organizations should evaluate the specific Part 253 applicability requirements for each source and activity rather than relying solely on facility-level emissions.

Reporting Timeline

The first reporting period under Part 253 began January 1, 2026, and covered entities are already subject to compliance requirements. Key dates include:

• September 1, 2026: Emissions Monitoring and Measurement Plans were due for applicable reporting entities.
• December 31, 2026: GHG Monitoring Plans are due for Large Emission Sources.
• June 1, 2027: Annual emissions reports covering calendar-year 2026 emissions are due.
• December 1, 2027: Verification statements for 2026 emissions are due for reporting entities subject to third-party verification.
• June 1 annually: Annual emissions reports are due for subsequent reporting years.

Organizations that were subject to the September 1 deadline but have not completed the required plan should address that requirement promptly while continuing to prepare for upcoming reporting and verification deadlines.

Understanding New York’s Reporting Requirements

Part 253 establishes specific requirements for calculating and reporting GHG emissions. Emissions must be reported in metric tons of CO₂e using methodologies prescribed by DEC, including the use of 20-year global warming potential values.

Organizations that already report emissions under other regulatory or voluntary programs should evaluate where their existing methodologies align with Part 253 and where New York’s definitions, emissions boundaries and calculation requirements differ.

Annual emissions reports will be submitted through the New York State Electronic Greenhouse Gas Emissions Reporting Tool (NYS e-GGRT). DEC is developing the electronic reporting system and plans to provide training before the first annual reports are due June 1, 2027.

Third-Party Verification Requirements

Part 253 classifies sources that meet higher, source-specific thresholds as “Large Emission Sources” and requires annual third-party verification of their emissions reports. For facilities, the threshold is 25,000 MT CO₂e annually, compared with the 10,000 MT CO₂e facility reporting threshold. Verification also applies to natural gas suppliers providing 15 million cubic feet or more annually; suppliers of affected liquid fuels and petroleum products providing 100,000 gallons or more; suppliers of coal providing 500 U.S. short tons or more; and waste haulers or transporters with 25,000 MT CO₂e or more in reportable emissions. These higher thresholds determine which reporting organizations must also obtain independent verification.

Reporting entities subject to verification must contract with a verification body accredited by DEC. For 2026 emissions data, verification statements are due December 1, 2027, six months after the first annual emissions reports are due.

Organizations that may meet a verification threshold should determine their obligations early and allow sufficient time for verification. Complete documentation, appropriate internal controls and support for emissions calculations will be important to an efficient verification process.

What Companies Should Do Now

With the 2026 reporting period underway and the first compliance deadline already passed, covered organizations should assess their progress and focus on the requirements that remain ahead. Priorities include:

• Confirm that all applicable facilities, fuels and activities have been identified.
• Review the Emissions Monitoring and Measurement Plan submitted in September and address any gaps in data collection or documentation.
• Determine whether the organization qualifies as a Large Emission Source and, if so, prepare for the December 31 GHG Monitoring Plan deadline.
• Evaluate whether existing emissions calculations and data collection processes meet Part 253 requirements.
• Establish controls and documentation to support the first annual emissions report due June 1, 2027.
• Identify third-party verification requirements and begin planning for the verification process, if applicable.

How Weaver Can Help

Weaver assists organizations with the technical and operational requirements of climate and emissions reporting, including emissions quantification, readiness assessments, governance and controls, verification preparation and ongoing reporting support.

For organizations subject to New York Part 253, continued preparation can help identify gaps in emissions data, calculation methodologies, documentation and internal controls before the first annual reports are due. Organizations subject to third-party verification can also use this time to prepare supporting documentation and address issues that could complicate the verification process.

During New York’s first year of mandatory GHG reporting, covered organizations should remain focused on meeting upcoming compliance requirements while establishing processes that can support accurate, consistent reporting in future years.

Contact us to learn more about preparing for New York’s GHG reporting requirements.

©2026

Featured

Evaluating Your Organization’s GHG Emissions Reporting ReadinessDownload

 

Executive Resource

Evaluating Your Organization’s GHG Emissions Reporting Readiness