How large emitters can prepare for New York's greenhouse gas verification requirements
At a glance
New York's Mandatory Greenhouse Gas Reporting Program (6 NYCRR Part 253) is entering a new phase. Large Emission Sources will be required to obtain independent third-party verification of reported greenhouse gas (GHG) emissions. The regulatory deadline for verification statements of GHG emissions for 2026 is December 1, 2027. Starting now gives your team more time to review data, strengthen documentation and prepare for verification.
What is New York's Mandatory Greenhouse Gas Reporting Program?
The DEC established 6 NYCRR Part 253 to collect information about GHG emissions across New York State. The program requires third-party verification of emissions reported by Large Emission Sources. Verification evaluates reported emissions data and associated calculations against DEC reporting procedures and must be completed by a verifier approved by DEC.
If you already participate in environmental reporting programs, elements of the process may be familiar. If this is your first independent review, early preparation can help reduce pressure during the verification cycle.
Who needs third-party verification?
Third-party verification applies to Large Emission Sources in New York State, including:
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Facilities with GHG emissions of 25,000 metric tons of carbon dioxide equivalent (CO2e) or more per year
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Natural gas suppliers providing 15 million cubic feet or more of natural gas annually
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Suppliers of liquid fuels and petroleum products providing 100,000 gallons or more of affected liquid fuels annually
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Waste haulers and transporters whose solid waste results in emissions of 25,000 metric tons CO2e or more per year from landfills or combustion facilities outside New York State.
If your operations meet one of these thresholds, consider how verification will fit into your reporting process and who will be responsible for preparing the supporting information.
Why verification preparation matters now
Preparing for verification begins well before your verifier issues a statement. Your team may need time to review GHG inventory methodologies, assemble supporting records and evaluate data quality.
Verification focuses on the reported emissions data and the calculations used to generate results. The objective is to determine whether emissions have been reported in accordance with DEC requirements and whether they fall within the program's required materiality thresholds.
Early planning can be valuable if your inventory covers multiple facilities or includes complex operational boundaries. It gives your team time to find missing information and address inconsistencies before the verification process begins.
How to prepare for verification
If your organization may be subject to the requirements, you can start by:
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Confirming which reporting thresholds apply to your operations
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Reviewing your GHG inventory methodology and calculation processes
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Evaluating the availability and quality of supporting records
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Identifying potential data gaps before the verification cycle begins
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Understanding the requirements for approved third-party verification bodies
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Developing a timeline that aligns reporting activities with the December 2027 regulatory deadline
Consider engaging a DEC-approved third-party verifier early enough to discuss timing, information requirements and verification readiness.
Prepare for New York’s GHG verification requirements
Preparing for the first verification deadline
The first verification statement may not be due until December 2027, but the quality of your submission will depend on decisions made much earlier. Have the data and calculations used to prepare your GHG report well organized prior to the verification. This will help the verification process go more smoothly.
New York joins a growing GHG verification movement
Greenhouse gas reporting and verification programs have been growing in popularity over the past several years. Our verification teams have experience providing verification services in programs across North America, including:
In the United States, GHD has completed hundreds of verifications for a wide sector of industries in multiple states, including over 600 regulatory verifications in California, Washington, Oregon, and Massachusetts, and over 200 verifications for voluntary programs such as The Climate Registry (TCR), the American Carbon Registry (ACR), the Climate Action Reserve (CAR) and the Verified Carbon Standard (VCS).
In Canada, GHD has completed over 1,000 verifications across multiple provinces, including British Columbia, Alberta, Saskatchewan, Ontario, Quebec, Nova Scotia, New Brunswick, and Newfoundland and Labrador, as well as for the Government of Canada.