Lillian Jordan, ELR Staffer ‘27

You can’t reduce what you don’t measure. On December 1, 2025, the New York State Department of Conservation (“DEC”) finalized a statewide greenhouse gas emissions reporting program (“GHG program”) that requires certain entities to monitor and report annual greenhouse gas emissions to the DEC. The regulation became effective December 25, 2025, with the first reporting year beginning in 2026. Emissions data for 2026 must be reported by June 1, 2027. The rule is data-collection focused and does not require emissions reductions. Instead, the reporting system is intended to support implementation of New York’s broader climate policies under the Climate Leadership and Community Protection Act (“CLCPA”).

The DEC published a list of in-scope reporting entities. Among others, these entities include suppliers of natural gas, electric power entities, and owners or operators of facilities in New York emitting at least 10,000 metric tons of carbon dioxide equivalent annually. The DEC also provides a GHG estimation tool to assist entities in calculating emissions from activities such as fuel combustion, landfills, and industrial production. Entities identified as “large emissions sources” must verify their reported emissions through a third party. 

New York’s program draws on established federal and state reporting frameworks, including the Environmental Protection Agency’s Greenhouse Gas Reporting Program and California’s Mandatory Reporting Regulation. At the federal level, major facilities have long been required to report greenhouse gas emissions under the EPA’s program. New York’s rule, however, expands beyond the federal framework by capturing additional sources, including fuel suppliers and emissions associated with in-state energy consumption. The program also mirrors California’s reporting system, which served as a precursor to its Cap-and-Invest program. This alignment suggests that New York’s reporting program may serve as a foundation for more comprehensive climate regulation. Further, at a time when the EPA is reconsidering the scope of its Greenhouse Gas Reporting Program, New York’s rule may also serve to fill potential emerging gaps in emissions data collection.

Emissions reporting programs are widely understood to be a prerequisite for effective climate regulation. The GHG program is a step toward greater emissions transparency in New York. The CLCPA aims to achieve a 40%reduction in greenhouse gas emissions by 2030 and at least an 85%reduction by 2050, relative to 1990 levels. By collecting standardized emissions data, the state can better track progress toward its statutory climate goals. As reporting begins this year, regulators and businesses will gain a clearer understanding of the sources of greenhouse gas emissions across the state and develop a more targeted climate policy.