We have a new entrant into the state-level GHG Reporting world, 6 NYCRR Part 253 (Mandatory GHG Reporting) is here!
If you have large sources of scope 1 emissions in NY, sell fuel/electricity into NY, supply large amounts of agricultural lime and fertilizer in NY, or run waste large operations/export in NY, annual GHG reporting is no longer “nice to have” — it’s a regulated filing.
The data gathered from this regulation will greatly inform how NY’s carbon market could play out with a potential Cap-and-Invest type policy.
Why New York’s Mandatory GHG Reporting Feels Familiar:
- It is like the federal EPA GHGRP (40 CFR Part 98) and California’s Mandatory Reporting Regulation (MRR). The regulations include requirements for defined methods, documentation, QA/QC, and deadlines.
- Similar to the California requirements, NY requires third-party verification for “Large Emission Sources”.
- The NY regulations calculates CO₂e using a 20-year global warming potential (vs the typical 100-year GWP) — which puts a brighter spotlight on near-term climate pollutants (especially methane).
If You’re a Large Emission Source, Expect a Real, Reasonable Level Audit Cycle, Not a Light Review.
- Verification is required annually once you cross the “Large” thresholds (e.g., facilities ≥25,000 MT CO₂e/year; plus supplier-specific thresholds).
- Timeline: emissions year 2026 is the first reporting year; first Emissions Data Report is due June 1, 2027.
- First Verification Statements are due Dec 1, 2027 (for 2026) and Dec 1, 2028 (for 2027), then Aug 10 in later years.
- How to get it done: you’ll need to contract with a DEC-accredited verification body (DEC is currently developing the website with the full list of verification bodies). The first year is a “full verification” (expect a site visit + deeper systems/data checks), with the next two years potentially less intensive if you earn a clean statement.
The practical takeaway is that 2026 is not a “dry run” year. It will be important to follow your established monitoring plan, initiate QA/QC procedures, iterate and improve processes, and start assembling an evidence package in preparation for verification. Note that certain reporters such as High-Emitting Solid Waste Landfills, Anaerobic Digester and Liquid Storage Operators will need to submit an Emissions Monitoring and Measurement Plan by September 1, 2026.
