New York GHG Reporting: 2026 Compliance Guide

Verification operates on a three-year cycle: full verification in year one (including site visit, sampling plan, data management review, and data checks), followed by less intensive verification for two years, but only if the source receives a "positive verification statement" in year one.

Non-Compliance Penalties Are Significant

The regulations establish substantial penalties for non-compliance:

• Each day a report is unsubmitted, late, or contains inaccurate/incomplete information = separate violation
• Each metric ton emitted but not reported = separate violation
• Each failure to measure or collect required information = separate violation

As White & Case illustrates: "In a situation where a Reporting Entity submits a report 30 days late, miscalculates emissions by five metric tons, and fails to properly collect one data point in accordance with its monitoring plan, that entity could face a maximum penalty of over $500,000."

New York vs. California SB 253: Understanding the Overlap

For companies operating across state lines, New York's MGGRP and California's SB 253 create parallel, but distinct, compliance obligations:

The key distinction between California’s climate rule and New York’s GHG reporting requirements: New York captures facility-level and supplier emissions including upstream impacts, while California captures enterprise-wide value chain emissions. Organizations subject to both must maintain flexible data systems capable of serving multiple frameworks.

Where Companies Get Stuck

The 20-GWP Calculation Gap: Most existing carbon inventories use 100-year global warming potentials. New York's 20-year GWP requirement means recalculating baseline emissions, and mixing methodologies creates audit risk.

Upstream Emissions Data: New York's requirement to report upstream, out-of-state emissions associated with fossil fuels and electricity consumed in the state adds complexity beyond typical direct emissions reporting.

Applicability Uncertainty: Determining whether operations fall within scope, particularly for companies with limited direct ties to New York, may require careful analysis.

Federal Rule Uncertainty: Many reporting obligations in the MGGRP cite federal rules. With the Trump administration proposing to end reporting for 46 source categories under the federal GHGRP, companies must monitor how changes could affect New York's program. NYSDEC has stated it "may" need to make corresponding changes if federal rules change.

Compressed Timeline: Since data collection requirements begin in 2026, Reporting Entities do not have significant time to prepare. Companies may need to act quickly.

How Leading Organizations Are Preparing

Organizations treating 2026 as a systems-building year — not a compliance scramble — are taking strategic steps:

Centralizing Emissions Data Management with Nasdaq Metrio

Rather than reconstructing data after the fact, companies are deploying dedicated sustainability reporting platforms to capture emissions continuously. Nasdaq Metrio is a comprehensive ESG and sustainability reporting solution that enables organizations to:

• Collect and centralize environmental data across facilities, suppliers, and operations
• Automate calculations aligned to regulatory methodologies, including 20-year GWP requirements
• Generate disclosure-ready reports that meet New York's upstream emissions documentation requirements
• Track performance against sustainability targets with real-time dashboards

The business impact is measurable. According to an independent Forrester Total Economic Impact™ study, organizations using Nasdaq Metrio achieved 213% ROI over three years, with payback in less than six months. The study found that Metrio helped companies reduce compliance reporting time by up to 75% while improving data accuracy and audit readiness.

Assessing Regulatory Readiness with Nasdaq Lens

With disclosure requirements proliferating — New York, California, the EU's CSRD — organizations need visibility into gaps before deadlines arrive. Nasdaq Lens is an AI-powered ESG gap assessment and disclosure management platform that:

• Analyzes current disclosures against climate-focused regulations
• Identifies gaps in data collection, methodology, and documentation
• Prioritizes remediation based on compliance deadlines and materiality
• Monitors regulatory changes to alert organizations to new requirements

Nasdaq Lens provides the visibility organizations need to move from reactive compliance to proactive readiness — identifying where gaps exist before regulators or auditors find them.

Building Strategic GHG Capabilities with Nasdaq Advisory

Compliance is the floor. Organizations moving beyond reactive reporting are engaging advisory support to develop GHG strategies, establish measurement protocols, and build verification-ready processes.

Nasdaq Sustainability & Climate Advisory provides practical guidance across the compliance journey:

• GHG inventory development — Establishing baseline emissions and measurement protocols
• Monitoring plan preparation — Developing documentation that meets NYSDEC requirements
• Verification readiness — Preparing for third-party verification with audit-ready processes
• Multi-jurisdictional alignment — Building systems that serve New York, California, and emerging frameworks

For organizations without established emissions tracking infrastructure, advisory support transforms what could be a daunting compliance exercise into a strategic capability-building opportunity.

Assess Your Readiness — Before Regulators Do

With the September 2026 deadline for monitoring plans approaching, organizations cannot afford to wait until 2027 to discover gaps in their emissions data infrastructure.

Nasdaq offers a complimentary AI-powered gap assessment to help organizations understand their climate reporting readiness vs. peers and other emerging disclosure requirements. The assessment analyzes your current sustainability disclosures and identifies specific gaps against regulatory frameworks — providing a prioritized roadmap for compliance.

Request Your Complimentary ESG Gap Assessment →

The Bigger Picture: Why This Matters

New York's program — alongside California's SB 253 and emerging frameworks in Washington and Oregon — is establishing a new baseline for corporate transparency. The program will impose a new administrative obligation on many industrial facilities in New York, and most entities selling fuels or electricity into New York.

For larger companies that already track greenhouse gas emissions, the requirements are manageable, though monitoring plans, the new reporting system, and first-time verification will still require effort. For smaller companies or those without established emissions tracking, the obligations will require external support.

The organizations that build robust systems now will be prepared for whatever requirements emerge next. The table is set. Preparation begins now.

New York GHG Reporting FAQ

What is the New York Mandatory Greenhouse Gas Reporting Program?

The New York Mandatory Greenhouse Gas Reporting Program (6 NYCRR Part 253) is a state-level emissions disclosure framework established by the New York State Department of Environmental Conservation (NYSDEC). Adopted on December 1, 2025, the program implements recommendations from the Climate Action Council under New York's 2019 Climate Leadership and Community Protection Act (CLCPA). Importantly, this is a data collection program only — it does not impose requirements to reduce GHG emissions or force sources to obtain emission allowances. The program will help ensure comprehensive New York State-specific information is available regarding individual sources of GHG emissions across the state.

Who needs to report to the New York GHG program?

"Reporting Entities" required to submit annual emissions data include:

• Facility owners and operators in New York State that emit 10,000 metric tons or more of CO₂ equivalent (CO₂e) per year
• Natural gas suppliers supplying any quantity to end users in New York State
• Liquid fuels and petroleum product suppliers supplying any quantity to New York end users
• LNG, CNG, and coal suppliers supplying any quantity to New York end users
• Waste haulers and transporters for which estimated emissions from solid wastes transported to out-of-state landfills or combustion facilities exceed 10,000 MT CO₂e per year
• Electric power entities that emit any GHG emissions or import megawatt hours (MWh) into New York State
• Suppliers of agricultural lime and fertilizer that supply quantities generating any GHG emissions per emission year
• Anaerobic digestion and liquid waste storage facilities where wastes imported or generated can produce 10,000 MT or more of CO₂e per year

What are New York's requirements for GHG disclosure?

New York's requirements are broader than federal standards. Reporting Entities must disclose:

1. Total GHG Emissions (in CO₂e): Calculated using 20-year global warming potentials
2. Emissions by Source Category: Stationary combustion, process emissions, fuel volumes, electricity generation, waste-related sources
3. Upstream, Out-of-State Emissions: GHG emissions associated with extraction, production, and transmission of fossil fuels and electricity consumed in New York, combustion of waste delivered outside of NY, electricity exported from and wheeled through NY
4. Activity & Product Data: data collection, tracking, and quality assurance processes
5. Assurance & Verification: Large Emission Sources must have their emissions verified by a third-party

Reporting will be submitted through the NYS e-GGRT (New York State Electronic Greenhouse Gas Emissions Reporting Tool), which NYSDEC is currently developing.

What are the key dates for the New York GHG compliance timeline?
 

What are the non-compliance penalties for the New York Greenhouse Gas Reporting Program?

The regulations establish substantial penalties for non-compliance:

• Each day a report is unsubmitted, late, or contains inaccurate/incomplete information constitutes a separate violation
• Each metric ton emitted but not reported constitutes a separate violation
• Each failure to measure or collect required information constitutes a separate violation

According to White & Case, "In a situation where a Reporting Entity submits a report 30 days late, miscalculates emissions by five metric tons, and fails to properly collect one data point in accordance with its monitoring plan, that entity could face a maximum penalty of over $500,000."