The rules will likely have an outsized impact on manufacturers and other industrial companies.
Key takeaways
Robust data collection and establishing internal audit processes are among key considerations.
Affected companies must start preparing now to ensure future compliance with regulations.
Businesses must navigate an increasingly complex and evolving regulatory landscape for sustainability reporting, and recent greenhouse gas reporting rules in New York state add another facet to that landscape. These rules will likely have an outsized impact on manufacturers and other industrial companies, given their higher emissions output compared to many other industries.
Effectively collecting, processing and analyzing emissions data is essential for regulatory compliance, while also giving businesses the ability to make informed strategic decisions. For companies doing business in New York, understanding current regulatory obligations and requirements, as well as those on the horizon, is critical.
Background and who is affected
Effective Dec. 1, 2025, the New York State Department of Environmental Conservation (DEC) adopted the Mandatory Greenhouse Gas Reporting Program (Part 253) as recommended by the Climate Action Council Scoping Plan. The reporting program requires certain reporting entities to annually report emissions and related data to the DEC.
Those affected include:
- Owners and operators of facilities that produce 10,000 metric tons or more of carbon dioxide equivalent per year
- Suppliers of natural gas to end users in New York state
- Suppliers of liquid fuels and petroleum products to end users in New York state
- Suppliers of compressed natural gas and liquefied natural gas to end users in New York state
- Suppliers of coal to end users in New York state
- Waste haulers and transporters if emissions from solid waste transported to landfills or combustion facilities outside of New York state exceeded 10,000 metric tons of carbon dioxide equivalent emissions in any year
- Electric power entities
- Owners and operators of anaerobic digestion and liquid waste storage if wastes imported to the facility or generated at the facility are in an amount that would generate 10,000 metric tons of carbon dioxide equivalent emissions in the reporting year
For those affected, emissions monitoring and measurement plans are due Sept. 1, 2026. The first emissions data reports are due to the DEC on June 1, 2027, for the year ended Dec. 31, 2026.
Certain entities that qualify as large emission sources are required to submit verification statements through a verification body accredited by the DEC. Those who qualify as large emission sources are required to submit a greenhouse gas monitoring plan by Dec. 31, 2026, as well as verification statements by Dec. 1, 2027, for the year ended Dec. 31, 2026. Those defined as large emission sources include:
- Owners and operators of facilities that meet or exceed 25,000 metric tons or more of carbon dioxide equivalent per emission year
- Suppliers of natural gas to end users in New York state that exceed 15 million cubic feet or more of natural gas per emission year
- Suppliers of liquid fuels and petroleum products to end users in New York state that exceed 100,000 gallons or more of liquid fuels or petroleum products per emission year
- Suppliers of compressed natural gas and liquefied natural gas to end users in New York state that exceed 15 million cubic feet or more of compressed and/or liquefied natural gas per emission year
- Suppliers of coal to end users in New York state that exceed 500 U.S. short tons of coal per emission year
- Waste haulers and transporters if emissions from solid waste transported to landfills or combustion facilities outside of New York state exceeded 25,000 metric tons of carbon dioxide equivalent emissions per emission year
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Organizations that have already taken action in response to California’s climate regulations—including implementing processes to improve emissions data collection and analysis—will be best positioned to respond to New York’s new rules, but all companies need to start assessing the implications.
There may also be more new reporting requirements soon. On Feb. 10, 2026, New York state’s proposed Climate Corporate Data Accountability Act (S9072A) passed the state Senate and has been delivered to the Assembly. The legislation, which significantly aligns with California’s Climate Regulation SB235, would mandate annual public disclosure of greenhouse gas emissions by companies with more than $1 billion in annual revenue that operate in New York, with reporting beginning as early as 2028. This would include the need for limited and reasonable assurance engagements.
Operational and compliance considerations for manufacturers
While New York’s Mandatory Greenhouse Gas Reporting Program applies to companies across industries, we anticipate manufacturing and industrial companies will be among the most affected.
Here are some operational and compliance action items for companies to consider:
Develop robust data collection and management systems to accurately track and report greenhouse gas emissions across all facilities and operations in accordance with New York state requirements
Train staff on the latest reporting protocols, measurement standards and documentation procedures mandated by the program
Establish internal audit and verification processes to maintain data integrity, reduce reporting errors and demonstrate compliance during state inspections or third-party reviews
Engage legal and compliance advisors to interpret regulatory updates, ensure timely submission of reports and address any discrepancies or enforcement actions from state agencies
Evaluate potential impacts on supply chains and product development, as suppliers and production processes may also need to meet new reporting or emissions standards under New York’s program
How companies can prepare
Working with a third-party advisor can help manufacturers and other industrial companies keep up with the evolving regulatory landscape, which will be critical considering some prior reporting regulation rollouts have had stops and starts.
The current program, effective Dec. 1, 2025, is intended for data collection purposes only, and New York state does not currently impose penalties based on emissions volumes. However, affected companies must start preparing now to ensure future compliance with applicable laws and regulations.
RSM contributors
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