On December 1, 2025, the Department of Environmental Conservation (DEC) announced that it finalized regulations establishing a Mandatory Greenhouse Gas Reporting Program.
Mandatory Greenhouse Gas Reporting Program Background
As part of her 2025 State of the State address, Gov. Hochul directed the New York State Energy Research and Development Authority (NYSERDA) and DEC to "take steps forward on developing the cap-and-invest program, proposing new reporting regulations to gather information on emissions sources, while creating more space and time for public transparency and a robust investment planning process." Pursuant to this directive, on March 26, 2025, DEC proposed draft GHG reporting regulations under 6 NYCRR Part 253. The final regulations, issued on December 1, 2025, will become effective 30 days after filing the Notice of Adoption with the Department of State.
Who Is Required to Report?
The final regulations require certain entities to annually report their GHG emissions via the New York State Greenhouse Gas Reporting Tool (NYS e-GGRT), beginning on June 1, 2027, for 2026 emissions.1 Specifically, the regulations require natural gas and liquid fuels suppliers, waste haulers and transporters, electric power entities, agricultural lime and fertilizer suppliers, and other large emissions sources that operate in New York after January 1, 2026, to report and verify their GHG emissions if they exceed certain relevant thresholds. (6 NYCRR Subpart 253-1.2). Some examples of large emission sources required to report include owners and operators of facilities with 25,000 metric tons or more of CO2e per emissions year and coal suppliers, while other sources that may be obligated to report include position holders at terminals owning affected liquid fuels, energy service companies who provide gaseous fuels to end users in New York, operators of interstate pipelines delivering gaseous fuels, importers of compressed natural gas or liquefied natural gas into New York, local distribution companies who are public utility gas corporations or publicly-owned natural gas utilities delivering gaseous fuels, electricity importers and exporters, and petroleum and natural gas systems.
Changes From Proposed Regulations to Final Regulations
As part of the final rulemaking package, DEC announced that based on public comments, it made certain changes to the proposed regulations that are intended to include additional flexibility for the regulated community. These changes include extending the verification reporting deadline for the first two years, changing the reporting requirement from three years to one year for facilities that closed or ceased operations during the emissions reporting year, and clarifying terms and definitions to better align with existing federal GHG reporting requirements.
Regarding this last point, on September 16, 2025, EPA proposed to amend the federal Greenhouse Gas Reporting Program to remove program obligations for most source categories, including the distribution segment of the petroleum and natural gas systems source category (subpart W—Petroleum and Natural Gas Systems), and suspend program obligations for the remaining subpart W segments until reporting year 2034.2 EPA's proposed regulations, if finalized, might lead to confusion with respect to the aspects of the Part 253 regulations that incorporate the federal regulations by reference. DEC acknowledged the potential need to address this issue in its Regulatory Impact Statement, in stating that "if changes are made by EPA or otherwise at the federal level to reduce or eliminate existing requirements or to make certain information unavailable, then the Department may need to make corresponding changes to Part 253."
DEC stated in its Assessment of Public Comments that it will provide outreach and technical assistance to reporting entities to aid in compliance with Part 253, which will require data collection related to GHG emissions starting in 2026. DEC also emphasized that the data verification requirements are reasonable because they are used in other reporting jurisdictions. However, in recognition of early verification deadlines, the final regulations extend the compliance dates for the first two years of verification. Verification in the form of statement for reporting 2026 and 2027 emissions, will be due on December 1, 2027, and December 1, 2028, respectively. Beginning with the 2028 emissions reporting, the verification deadline will return to August 10 of each year subsequent to the year of reported emissions.
Key Deadlines
There are several other key deadlines and compliance requirements specified in the final regulations and listed below.
| Regulatory Provision | Reference |
| The department must approve any postponement of calibration or required recalibration beyond January 1, 2026. | 253-1.4(g)(9) |
| A written request for postponement must be submitted to the department by July 1, 2026, or not less than 30 days before any subsequent required calibration, recalibration, or inspection date. | 253-1.4(g)(9)(i) |
| The operator of an applicable solid and liquid waste management facility or operation must submit an Emissions Monitoring and Measurement Plan (EMMP) proposal to the department no later than September 1, 2026, and by March 1, 2029, and every three years thereafter in a format approved by the department. | 253-2.20(a)(2) |
Conclusion
While the Part 253 reporting regulations do not impose emission reduction requirements, the State's actions are a necessary first step in doing so. Finalizing these rules may reflect an intent to show progress on climate related actions, following a recent court decision requiring DEC to promulgate climate regulations.
Footnotes
1 While the NYS e-GGRT electronic reporting platform is currently being developed, relevant information on the Mandatory Greenhouse Gas Reporting Program is available here: Mandatory Greenhouse Gas Reporting – NYSDEC. Additionally, DEC estimates that reporting costs result in a low of just over $17,500 and a high of just over $91,000 per facility per year, and verification to be an additional cost of $4,000 annually for the simplest facilities up to $17,000 annually for the most complex facilities and fuel suppliers.
2 90 Fed. Register 44591 (September 16, 2025).
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