Impacts, Risks, and Opportunities (IRO) for CSRD Reporting
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In this article, we’ll break down what IROs are, how to identify and assess them, and what CSRD requires in terms of disclosure.
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Industries
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New York GHG Reporting Regulations: Everything you need to know
Level
New York is introducing a new mandatory greenhouse gas (GHG) reporting framework that will require a wide range of companies to start measuring and disclosing emissions data at the state level. The rules will not only apply to large emitting facilities, but also to fuel suppliers, electricity importers, waste operators, and other entities whose activities are linked to New York - including some based outside the state.
With emissions data collection beginning in 2026 and the first reports due in 2027, the program signifies a significant change in compliance obligations for many organisations - especially those that were not previously subject to state-level climate reporting.
In this article, we'll cover:
What New York’s new GHG reporting requirements are and why they were introduced
Which facilities, suppliers, and operators are required to report
What emissions data must be submitted, and how it is calculated
Key reporting and verification timelines
How the New York framework compares to other US climate reporting rules
What are the new New York GHG reporting requirements?
New York State has finalised a mandatory greenhouse gas (GHG) reporting program that significantly expands who must measure and report emissions data at the state level. From 2026 onwards, a wide range of facilities, fuel suppliers, electricity providers, and waste operators linked to New York will be required to quantify their greenhouse gas emissions and submit annual reports to the New York State Department of Environmental Conservation (DEC).
Established under 6 NYCRR Part 253, the program is designed to create a comprehensive, New York–specific emissions dataset in support of the state’s Climate Leadership and Community Protection Act (CLCPA). While the rules do not impose emissions limits or reduction targets, they introduce a new layer of regulatory reporting that many organisations, including some based outside New York, may not expect to fall within scope.
The reporting framework focuses on data collection. Reported emissions feed into the state’s annual greenhouse gas inventory and will help shape future climate and air quality policies.
Why has New York introduced a mandatory GHG reporting program?
New York introduced its mandatory GHG reporting program to support the Climate Leadership and Community Protection Act (CLCPA), which requires the state to track greenhouse gas emissions across the economy using consistent, reliable data.
Existing federal and state reporting systems do not capture all emissions linked to New York, particularly those associated with fuel supply, electricity imports, waste transport, and certain industrial activities. As a result, the state has relied in part on aggregated or estimated data.
The new program closes these gaps by creating a New York–specific emissions dataset that feeds directly into the state’s annual greenhouse gas inventory. The framework is designed for data collection only and does not impose emissions limits or reduction obligations.
Who is required to report under New York’s GHG reporting rules?
New York’s GHG reporting program applies to a wide range of entities with activities that generate greenhouse gas emissions in, or linked to, New York State. Reporting obligations are based on activity type and emissions thresholds, rather than company revenue or corporate structure.
🏭 Facilities located in New York State
Owners and operators of facilities in New York must report if the facility emits 10,000 metric tons CO₂e or more per year.
Electricity generation and stationary combustion facilities
Landfills and waste-to-energy facilities
Natural gas compressor stations and related infrastructure
⛽ Fuel suppliers
Fuel suppliers must report if they supply fuel to end users in New York.
Natural gas
Liquid fuels and petroleum products
Liquefied and compressed natural gas (LNG and CNG)
Coal
Note: There is no minimum emissions threshold for fuel suppliers.
⚡ Electric power entities
Electric power entities are required to report if they:
Emit any GHG emissions linked to electricity generation, or
Import megawatt-hours (MWh) of electricity into New York
This captures electricity importers as well as certain exporters and retail providers.
🚛 Waste haulers and transporters
Waste haulers and transporters must report if the solid waste they transport to landfills or combustion facilities outside New York would generate more than 10,000 metric tons CO2e per year.
🌾 Agricultural and waste processing activities
Reporting obligations also apply to:
Suppliers of agricultural lime and fertiliser licensed in New York
Facilities used in anaerobic digestion or liquid waste storage, including certain wastewater treatment plants and concentrated animal feeding operations
These activities are subject to reporting when emissions meet applicable thresholds.
🌍 A note on out-of-state entities
Companies do not need to be based in New York to fall within scope. Entities located outside the state may still be required to report if they supply fuel, electricity, or waste-related services that generate emissions attributable to New York.
What emissions and data must be reported?
Reporting entities must submit an annual greenhouse gas emissions data report to the New York State Department of Environmental Conservation (DEC). Emissions must be reported in metric tons of carbon dioxide equivalent (CO2e).
Emissions covered
For most entities, reported emissions will include greenhouse gases released from:
Fuel combustion
Industrial processes
Waste management and transport activities
Electricity generation and imports, where applicable
The program focuses on direct emissions and activity-based emissions linked to operations or supply into New York, rather than corporate value-chain reporting.
Calculation methods
Emissions are calculated using standardised formulas and emission factors set by the DEC, based on activity data such as fuel volumes, electricity imports, or material throughput. In many cases, reporting entities submit activity or product data, which is converted into emissions values within the state’s reporting system.
Global warming potential
For this reporting program, emissions must be calculated using 20-year global warming potential values (GWP20). This means greenhouse gases are measured based on their warming impact over the next 20 years, rather than over 100 years as used in some federal and corporate reporting frameworks. This differs from some federal and corporate reporting frameworks that rely on 100-year GWP values.
Additional data requirements for certain sectors
Some facilities, including those in emissions-intensive industrial sectors, must also report product or activity data alongside emissions totals. This information is used to improve the accuracy of the state’s emissions inventory and inform future policy design.
What are the key reporting timelines and key deadlines?
New York’s GHG reporting obligations are based on calendar-year emissions and follow an annual reporting cycle.
Data collection begins: 1 January 2026
First reporting deadline: 1 June 2027 (for 2026 emissions)
Ongoing reporting: annually by 1 June for the previous year
Reporting must be submitted electronically via the New York State greenhouse gas reporting system.
Ongoing obligations
Once an entity becomes subject to reporting, it must continue to report until emissions fall below the applicable threshold for three consecutive years. Facilities that permanently cease operations are generally required to report for one additional year only.
How does reporting work in practice?
Emissions data must be submitted electronically using a New York State reporting system developed by the New York State Department of Environmental Conservation (DEC).
The state is rolling out a dedicated New York State Greenhouse Gas Reporting Tool (NYS e-GGRT) ahead of the first reporting deadline in June 2027. This platform will allow reporting entities to enter fuel, energy, or activity data, which is then converted into greenhouse gas emissions using DEC-approved calculation methods.
Ahead of the platform’s launch, DEC is also providing a non-binding estimator tool to help organisations understand their potential reporting obligations. This tool is for guidance only and cannot be used to determine whether an entity is legally required to report.
Reporting is required once per year and follows a similar structure to existing federal emissions reporting systems, helping reduce the learning curve for entities already reporting under EPA programs.
Verification requirements and large emission sources
Only certain reporting entities are required to have their emissions data independently verified. These entities are classified as Large Emission Sources under New York’s rules.
What is a Large Emission Source?
A reporting entity is considered a Large Emission Source if it meets or exceeds specific thresholds, including:
🏭
Facilities
Facilities: 25,000 metric tons CO2e or more per year
🔥
Natural gas suppliers
Natural gas suppliers: 15 million cubic feet or more per year
⛽
Liquid fuel and petroleum suppliers
Liquid fuel and petroleum suppliers: 100,000 gallons or more per year
🧊
LNG and CNG suppliers
LNG and CNG suppliers: 15 million cubic feet or more per year
🪨
Coal suppliers
Coal suppliers: 500 short tons or more per year
🚛
Waste haulers and transporters
Waste haulers and transporters: 25,000 metric tons CO2e or more per year
What does verification involve?
Large Emission Sources must have their emissions reports reviewed by a third-party verifier accredited by the DEC. Verification assesses whether emissions have been calculated and reported in line with New York’s requirements.
For the first reporting year, verification typically includes a more detailed review. If no material issues are identified, entities may qualify for less intensive verification in subsequent years.
Verification deadlines
Verification statements are submitted separately from emissions reports. For emissions year 2026, verification statements are due by 1 December 2027. For emissions year 2027, the deadline is 1 December 2028, after which verification statements are due annually by 10 August.
Monitoring and planning requirements
While all reporting entities must maintain monitoring documentation, only certain entities - including Large Emission Sources - are required to submit monitoring plans to the DEC for review.
Monitoring plans
Reporting entities are required to document how emissions data is collected, calculated, and managed. Monitoring plans must typically set out:
👤
Who is responsible for emissions data collection and reporting
📏
What data sources and measurement methods are used
🗂️
How data quality, maintenance, and record-keeping are managed
Large Emission Sources must submit their monitoring plan to the New York State Department of Environmental Conservation (DEC) for review.
Additional requirements for methane-intensive activities
Facilities engaged in anaerobic digestion, liquid waste storage, or certain waste management activities may also be required to submit a separate Emissions Monitoring and Measurement Plan focused on methane emissions.
These plans must be updated as operations or monitoring methods change and are intended to support accurate, consistent reporting over time.
Penalties and enforcement approach
New York’s GHG reporting program includes significant penalties for non-compliance, although the state has indicated that it will initially focus on education and outreach.
Each of the following may be treated as a separate violation:
📄
Failing to submit a required emissions report or verification statement
⏰
Submitting a report late
⚠️
Submitting incomplete or inaccurate information
🗃️
Failing to collect or retain required data
Penalties can apply per day and per metric ton of emissions not reported, meaning small errors or delays can accumulate quickly. In its early years, DEC has indicated it will prioritise helping entities understand and meet their obligations before moving to formal enforcement.
How does New York’s GHG reporting compare to other US frameworks?
New York’s GHG reporting program sits alongside, but is distinct from, other US climate reporting frameworks. While there is some alignment, the purpose and scope differ in important ways.
🇺🇸 Comparison with the federal EPA GHGRP
New York’s program draws on methodologies used in the EPA Greenhouse Gas Reporting Program (40 CFR Part 98), which helps reduce duplication for entities already reporting at federal level. However, New York’s rules:
Cover a broader set of activities linked specifically to New York
Capture emissions from fuel suppliers, electricity imports, and waste transport more comprehensively
Use 20-year global warming potential (GWP20) rather than 100-year values
The state program also remains in force regardless of future changes to federal reporting requirements.
🇺🇸 Comparison with California SB 253
New York’s reporting program is fundamentally different from California’s SB 253:
Scope: New York applies activity- and emissions-based thresholds; SB 253 applies to large companies based on revenue
Emissions covered: New York focuses on emissions tied to specific facilities and activities; SB 253 requires corporate Scope 1, 2, and 3 disclosures
Purpose: New York is building a state-owned emissions dataset; SB 253 is designed to increase corporate transparency for investors and regulators
For companies operating across multiple states, this means compliance may require parallel reporting systems tailored to different regulatory objectives.
What does this mean for companies operating in or supplying to New York State?
For many organisations, New York’s GHG reporting program introduces a new administrative obligation, even where emissions reporting is already in place under other frameworks.
Companies may need to:
Confirm whether their activities trigger reporting, particularly for fuel supply, electricity imports, and waste transport
Put systems in place to collect and retain activity data from 2026 onwards
Prepare for third-party verification if classified as a Large Emission Source
Coordinate emissions data across facilities, suppliers, and service providers
Entities with limited prior experience in emissions reporting may face a steeper learning curve, while multi-state operators will need to manage compliance across different reporting rules and timelines.
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