1. What New York'S Part 253 Reporting Program Requires
Part 253 grows out of the Climate Leadership and Community Protection Act and gives the DEC a statewide view of greenhouse gas emissions. It became effective on December 25, 2025, and it applies across the state rather than to a single city or sector.
A Reporting Rule, Not an Emissions Cap
Part 253 is a data-collection rule, so it does not set emission limits or require reporters to buy allowances. That distinction matters, because building caps and allowance markets are separate programs with their own greenhouse gas regulations and deadlines.
Reporting through the Nys E-Ggrt System
Reporting entities will file annual emissions and activity data through the New York State e-GGRT platform, which the DEC is still building. Until that system opens, covered entities should confirm their category and start gathering source data.
2. Who Must Report Emissions under Part 253
Coverage depends on the type of source and, for several categories, on an emissions or activity threshold. Identifying the correct category is the first step in determining a business's reporting obligations.
Facilities, Fuel Suppliers, and Electricity Entities
The program reaches well beyond large factories, and its main reporting categories include:
- Facilities emitting 10,000 metric tons of CO2e or more per year, or any CO2 Budget Source under Part 242
- Suppliers of natural gas, liquid fuels, compressed or liquefied natural gas, coal, agricultural lime, and fertilizer
- Electric power entities that import or export any electricity in New York
- Waste haulers whose out-of-state waste emissions exceed 10,000 metric tons of CO2e
How the Thresholds Apply
Facilities measure against the 10,000 metric ton threshold using a 20-year global warming potential, which can pull in sources that earlier rules missed. Fuel and electricity suppliers often report based on any quantity supplied rather than a numeric emissions floor.
3. Part 253 Compliance Deadlines in New York
P>The program phases in obligations over several years, moving from monitoring plans to verified annual reports. On July 31, 2026, the DEC issued an enforcement discretion letter that delayed enforcement of several of these deadlines.
| Requirement | Original Deadline | Enforcement Discretion Effective Through |
|---|---|---|
| Emissions Monitoring and Measurement Plan (waste facility operators) | September 1, 2026 | March 1, 2027 |
| Large Emission Source GHG Monitoring Plan | December 31, 2026 | June 30, 2027 |
| Registration for imported or exported electricity sources | February 1, 2027 | August 31, 2027 |
| First Emissions Data Report (2026 emissions) | June 1, 2027 | December 31, 2027 |
| Verification statement (2026 emissions) | December 1, 2027 | April 1, 2028 |
Why the 2026 Deadlines Shifted
The DEC granted enforcement discretion partly because it is amending Part 253 after the May 2026 changes to the Climate Act. DEC's enforcement discretion delays enforcement of specified deadlines but does not eliminate the underlying Part 253 reporting requirements.
4. Third-Party Verification for Large Emission Sources
Some reporters must have their data checked by an independent verifier accredited by the DEC. This requirement reaches only the largest sources, not every reporting entity.
Which Reporters Need Verification
Verification applies to large emission sources, such as facilities at or above 25,000 metric tons of CO2e per year and coal suppliers above 500 short tons. Suppliers of natural gas, liquid fuels, and similar products face their own volume-based verification thresholds.
The Three-Year Verification Cycle
Verification runs on a three-year cycle, with a full review and site visit in the first year and lighter interim checks in the next two. The first verification statement for 2026 emissions is subject to a separate enforcement-discretion date of April 1, 2028.
5. How Reporting Differs from Other New York Carbon Rules
Part 253 operates alongside other New York climate programs, but each program has a different trigger, obligation, and enforcement framework. Knowing which program applies to your operations helps prevent missed obligations.
Reporting Versus Local Law 97 Building Caps
Local Law 97 sets emissions caps on large New York City buildings and charges penalties for exceeding them, while Part 253 only collects data statewide. A city building owner can face both a municipal cap and a state reporting duty at the same time.
Reporting Versus Rggi, Cap-and-Invest, and Federal Rules
RGGI requires fossil-fuel power plants to hold allowances, and the state's proposed Cap-and-Invest program remains in development. Part 253 is separate from these and from any federal EPA reporting, so meeting one obligation does not satisfy another.
6. Managing Reporting Risk and Enforcement
Accurate, on-time reporting is the core of carbon emissions compliance under Part 253. Careful preparation in 2026 can affect the accuracy and completeness of a company's first report.
What Happens after a Late or Inaccurate Report
Reporting failures can draw DEC scrutiny under its energy regulatory enforcement authority, even though Part 253 sets no emission limits. Reporting discrepancies identified during verification may require correction and can become relevant in later regulatory reviews or transaction due diligence.
Building a Reliable Reporting Process
Start by confirming your reporting category, then assemble source data and a monitoring plan before the enforcement-discretion dates arrive. Keeping calculations, plans, and correspondence organized makes both annual reporting and later verification far easier.
7. Frequently Asked Questions
Who must report greenhouse gas emissions under New York's Part 253?
Facilities at or above 10,000 metric tons of CO2e per year must report, along with fuel suppliers, electric power entities, and certain waste transporters. Many suppliers report based on any quantity supplied, so smaller operations can still be covered.
When is the first Part 253 emissions report due?
The first report covers 2026 emissions and was originally due June 1, 2027, but the DEC's 2026 enforcement discretion moved that date to December 31, 2027. Earlier monitoring-plan deadlines still apply, so preparation cannot wait until 2027.
Which reporters need third-party verification?
Only large emission sources need verification, such as facilities at or above 25,000 metric tons of CO2e per year. Those reporters must hire a DEC-accredited verifier and follow the three-year verification cycle.
09 Feb, 2026
