In December 2025, the New York State Department of Environmental Conservation finalized a Mandatory Greenhouse Gas Reporting Program that will come into force in June 2027. Under this regulation, entities meeting the emissions threshold will be required to report their greenhouse gas emissions annually, covering emissions from the previous calendar year. 𝗞𝗲𝘆 𝗲𝗹𝗲𝗺𝗲𝗻𝘁𝘀 𝗼𝗳 𝘁𝗵𝗲 𝗿𝘂𝗹𝗲 𝗶𝗻𝗰𝗹𝘂𝗱𝗲: 𝗘𝗺𝗶𝘀𝘀𝗶𝗼𝗻 𝘁𝗵𝗿𝗲𝘀𝗵𝗼𝗹𝗱: Facilities emitting 10,000 metric tons of CO₂-equivalent or more per year will be required to report their emissions. 𝗜𝗻𝗱𝘂𝘀𝘁𝗿𝘆 𝗰𝗼𝘃𝗲𝗿𝗮𝗴𝗲: The requirement applies across a wide range of sectors, including power generation, industrial operations, fuel suppliers, natural gas infrastructure, waste-to-energy plants, and landfills. 𝗩𝗲𝗿𝗶𝗳𝗶𝗰𝗮𝘁𝗶𝗼𝗻 𝗿𝗲𝗾𝘂𝗶𝗿𝗲𝗺𝗲𝗻𝘁𝘀: Larger emitters must obtain third-party verification of their emissions data, strengthening credibility and alignment with global assurance practices. 𝗥𝗲𝗽𝗼𝗿𝘁𝗶𝗻𝗴 𝗽𝗹𝗮𝘁𝗳𝗼𝗿𝗺: Emissions data will be submitted through the New York State Electronic Greenhouse Gas Emissions Reporting Tool (NYS e-GGRT), a dedicated digital system being developed to streamline reporting and improve data consistency. This framework establishes a clear, standardized approach to emissions disclosure across the state, laying the groundwork for reliable, comparable, and decision-useful emissions data.
The reporting requirement applies broadly across emissions-intensive activities, reflecting New York’s intent to capture a comprehensive and economy-wide emissions picture. Entities required to report GHG emissions include electricity generation facilities, stationary combustion sources, natural gas compressor stations, industrial operations, landfills, waste-to-energy plants, and other infrastructure that exceeds the emissions threshold. Fuel suppliers of natural gas, petroleum products, coal, and other liquid fuels are also covered. In addition, certain agricultural inputs and waste-related activities fall within scope when emissions reach reportable levels. For the largest emitters, the regulation introduces mandatory third-party verification of reported emissions. This assurance requirement strengthens data credibility and aligns the state’s reporting framework with emerging international disclosure and verification practices. Following public consultation, the final rule incorporates practical flexibility for early reporting years, including extended verification timelines and reduced obligations for facilities that have ceased operations. Together, these provisions aim to balance data integrity with operational feasibility as organisations adapt to the new reporting regime.
To support implementation of the reporting programme, New York is developing robust digital infrastructure for greenhouse gas emissions reporting. Covered entities will submit emissions data through the New York State Electronic Greenhouse Gas Emissions Reporting Tool (NYS e-GGRT), an electronic platform designed to streamline submissions and improve data consistency across sectors. The platform is expected to standardize reporting formats, reduce administrative complexity, and enable long-term analysis of emissions trends at the state level. Guidance and training are expected to accompany the system’s rollout to support organizations as they prepare for compliance. In addition, the state has released a GHG estimation tool to help organizations assess potential reporting obligations related to fuel combustion, industrial processes, waste management, and upstream activities. While the tool is illustrative and does not determine legal reporting requirements, it provides an early reference point for companies to understand their carbon accounting and emissions profile and begin internal readiness planning.
New York’s mandatory GHG disclosure framework marks a shift from voluntary reporting to standardized, state-enforced emissions data. Key implications include:
Emissions disclosures will be more consistent and, for larger emitters, independently verified, reducing reliance on self-reported claims.
Reliable emissions data will support improved climate risk assessments, capital allocation decisions, and transition planning.
Companies aligned early with New York’s framework will be better prepared for evolving disclosure requirements across other states and global markets.
Standardized emissions data strengthens comparability, supporting investor analysis, portfolio assessment, and long-term value evaluation.
Overall, emissions data will increasingly function as decision-grade infrastructure, influencing both regulatory outcomes and financial strategy.
Although mandatory reporting begins in 2027, organizations that are likely to fall within scope should begin preparing well in advance. Early preparation will be critical to avoiding last-minute compliance risks and ensuring emissions data can be used effectively beyond regulatory reporting. Key areas of focus should include establishing robust GHG accounting frameworks across Scope 1, Scope 2, and relevant Scope 3 categories; strengthening internal data governance and controls, and assessing readiness for third-party verification. Organizations should also begin aligning New York’s reporting requirements with existing sustainability and climate disclosures to reduce duplication and improve consistency across frameworks. By starting early, companies can move beyond a reactive climate regulation compliance approach and position emissions data as a strategic input into risk management, investment planning, and long-term transition strategies.
As emissions reporting requirements expand and regulatory expectations evolve across jurisdictions, organizations require more than technical compliance support. They need structured, strategic guidance to navigate complexity while maintaining credibility and operational efficiency. Cognitud works with businesses to translate disclosure obligations into actionable ESG strategies that support long-term resilience and value creation. Cognitud supports organizations across the full disclosure journey, from designing robust greenhouse gas accounting frameworks aligned with regulatory thresholds, to strengthening data governance and assurance readiness. By helping organizations improve data quality, internal controls, and verification preparedness, Cognitud enables credible and decision-useful disclosures. Beyond reporting, Cognitud works with organizations to leverage emissions data as a foundation for climate strategy and decarbonization planning. This includes integrating state-level reporting requirements with broader sustainability and climate disclosures, reducing duplication, and ensuring consistency across frameworks. Through capability building and advisory support, Cognitud helps organisations embed emissions management into everyday decision-making and move beyond compliance toward data-driven climate leadership.
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Abhigyan Gupta
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Greenhouse gas emissions are gases released into the atmosphere that trap heat and contribute to global warming. The main greenhouse gases include carbon dioxide (CO₂), methane (CH₄), nitrous oxide (N₂O), and fluorinated gases. These emissions primarily come from activities such as energy use, transportation, industrial processes, agriculture, and waste.
GHG emissions can be reduced by improving energy efficiency, switching to renewable energy, reducing fossil fuel use, optimising industrial processes, improving supply chains, and using cleaner transport and materials. Measuring emissions accurately is the first step toward reducing them.
Yes. Carbon emissions, especially carbon dioxide are the largest contributor to climate change. They trap heat in the Earth’s atmosphere, leading to rising global temperatures, extreme weather events, sea-level rise, and long-term environmental and economic impacts.
Regulations create consistency, transparency, and accountability. Without regulation, emissions data is often incomplete or inconsistent. Regulatory frameworks ensure that companies measure and disclose emissions in a comparable, credible way, supporting better decision-making by investors, regulators, and businesses.
A climate risk assessment evaluates how climate-related risks such as physical impacts, regulatory changes, and market transitions could affect an organisation’s operations, finances, and long-term strategy. It helps organisations plan for resilience and risk management.
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