New York has implemented mandatory greenhouse gas (GHG) emissions reporting under the Climate Leadership and Community Protection Act (CLCPA), starting with 2026 emissions. The CLCPA established statewide targets of a 40% reduction in GHG emissions (versus the 1990 baseline) by 2030 and an 85% reduction by 2050.
Mandatory Greenhouse Gas Emissions Reporting
The most significant obligation for companies is mandatory GHG emissions reporting (6 NYCRR Part 253). Facilities located in New York that emit 10,000 metric tons or more of carbon dioxide equivalents (CO₂e) per year and specific entities, such as fuel suppliers, utilities, and the waste sector, are required to report GHG emissions beginning with calendar year 2026 data. Applicable entities were required in January 2026 to begin collecting their GHG emissions data to be reported in 2027.
The primary obligations under CLCPA include a GHG monitoring plan, an annual emissions data report, and third-party verification for large emission sources. Important deadlines for affected companies are as follows:
- December 31, 2026: Large Emission Source’s GHG Monitoring Plan
- June 1, 2027: First Emissions Report for 2026 data
- December 1, 2027: Third-party verification (if required)
Air Permitting and Climate Impact Analysis
For new Air State Facility permits, Title V permits, or significant permit modifications, the New York State Department of Environmental Conservation requires applicants to conduct a climate impact analysis to quantify direct GHG emissions from new or modified sources, as well as upstream and downstream emissions attributable to proposed projects. Climate impact analyses may affect project scopes, permitting timelines, and approvals.
Climate Corporate Data Accountability Act (Proposed)
On February 10, 2026, the New York State Senate passed the Climate Corporate Data Accountability Act (CCDAA). The bill is not yet law but is expected to advance following assembly action and governor signature.
If enacted, the CCDAA would require companies with over $1 billion in annual revenue doing business in New York to disclose Scope 1, 2, and 3 GHG emissions. Companies would be required to publicly disclose this information and achieve third-party assurance. The act has a phased timeline, requiring Scope 1 and 2 emissions reporting beginning in 2028 for the prior calendar year (2027) and Scope 3 emissions reporting beginning in 2029 (for 2028).
Questions? We’re Here to Help.
Companies operating in New York should evaluate the applicability of GHG emissions reporting requirements to their operations, confirm internal responsibilities, and ensure appropriate systems and processes are in place to support compliance with current and emerging requirements. For assistance with applicability determinations, emissions tracking, or compliance planning, please contact Bruce Martin at Bruce.Martin@ehs-support.com or Liz Hoerning at Liz.Hoerning@ehs-support.com.
