Expert Analysis | New York businesses subject to reporting regulations for greenhouse gas emissions amNewYork

"Manhattan skyline Photo by Andrew Denney The New York State Department of Environmental Conservation (DEC) recently finalized regulations establishing a mandatory greenhouse gas reporting program under New York Codes, Rules and Regulations Part 253. With the adoption of the regulation, New York becomes the third state to require emissions reporting, and the new rule shares a number of similarities with California's emissions reporting rules."

"This rule implements a key provision of the Climate Leadership and Community Protection Act (CLCPA), which mandates aggressive statewide GHG reductions: 40% by 2030 and 85% by 2050 from 1990 levels. The rule aims to build a comprehensive emissions database to help meet the state's CLCPA goals. While the regulatory program was a requirement of the CLCPA, directing DEC to compile accurate emissions data for large-quantity GHG generators,"

"Furthermore, it appears Gov. Kathy Hochul's administration took the action in response to the Trump administration's dismantling of the EPA's GHG Reporting Program, an action that again places individual states in the role as primary enforcers of climate change regulations. Still, the state was open to feedback on the emissions reporting rules. DEC released draft regulations in March 2025, drawing over 3,000 public comments, leading to adjustments, such as extended verification deadlines."

The regulation establishes a mandatory greenhouse gas reporting program under New York Codes, Rules and Regulations Part 253 to compile a comprehensive emissions database. The program supports CLCPA targets of 40% GHG reduction by 2030 and 85% by 2050 from 1990 levels and satisfies RGGI requirements to track CO2 from large fossil-fuel power plants. The state action followed the federal rollback of the EPA GHG Reporting Program. DEC released draft regulations in March 2025, received over 3,000 public comments, and adjusted requirements such as extended verification deadlines. Entities emitting at least 10,000 metric tons of CO2 annually, including power plants, industrial facilities, landfills, waste-to-energy facilities, anaerobic digesters, fuel suppliers and waste haulers transporting emissions-generating waste out of state are subject to reporting.

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