Which one applies depends on what you operate and where you do business, not on whether you want to report. The sections below cover who has to report, the thresholds, the deadlines, and what has changed recently, since the federal picture moved significantly in 2025 and 2026.
Who has to do emissions reporting in the US?
- Facilities emitting 25,000 tonnes of CO2e a year or more report to the EPA's Greenhouse Gas Reporting Program, along with suppliers of fossil fuels and industrial gases and sites injecting CO2 underground.
- Facilities in California and Washington above 10,000 tonnes report to their state regulator, and certain Oregon sectors report above 2,500 tonnes.
- Companies doing business in California with revenue above $1 billion report Scope 1 and 2 for reporting year 2026 and Scope 3 for 2027 under SB 253, with third-party verification. See our SB 253 solution.
- Companies above $500 million in California revenue publish a climate-related financial risk report under SB 261.
- Companies with EU operations above the CSRD thresholds report Scope 1, 2 and 3 with assurance. See our CSRD solution.
- Everyone else usually reports because a customer, a bank or an investor asked, through CDP or a direct data request.
What changed in 2025 and 2026
The article below was written in 2022, when federal expansion looked likely. That did not happen, and two developments matter for planning.
- The SEC climate disclosure rule. Adopted in March 2024, stayed by the courts within weeks, and never in effect. The SEC ended its legal defense of the rule in 2025 and proposed rescinding it in May 2026. There is no federal corporate climate disclosure requirement today.
- The GHGRP. In 2025 the EPA proposed cutting back GHGRP reporting requirements for most sectors rather than expanding them. Because that proposal has moved through several stages, confirm the current status of your subpart with the EPA before you skip a filing.
Federal retreat has not reduced the total reporting workload, because California and the EU picked up the corporate-level requirements. For companies with revenue in both places, the practical answer is one greenhouse gas inventory that can be exported to each. Our sustainability reporting guide maps the requirements against each other.
What data does emissions reporting require?
Every program reduces to the same four inputs.
- Activity data. Fuel burned, electricity purchased, refrigerant leaked, tonnes processed, miles driven, dollars spent with suppliers.
- Emission factors. Published coefficients that convert each activity into CO2e, with the source and the version recorded. Federal and state programs prescribe the calculation methods for each source category.
- An organizational boundary. Which facilities and entities are in, and on what basis, whether operational control, financial control or equity share.
- Evidence. A source document behind every number, since state programs and SB 253 require third-party verification.
Gravity's utility bill management collects the energy half automatically from bills and utility APIs, and carbon accounting applies the factors and keeps the evidence attached. For value chain data, see our Scope 3 guide and the explanation of Scope 1, 2 and 3.
The US emissions reporting picture as of 2022
With several different reporting programs and emissions thresholds in the United States, the landscape and interplay of greenhouse gas reporting regulations can be difficult to track. At the federal level, the Greenhouse Gas Reporting Program (GHGRP) serves as the primary national regulator of emissions data. At the state level, California, Oregon, and Washington have implemented more stringent reporting requirements for in-state companies and facilities.
This post offers a high-level overview of key aspects in the existing mandatory greenhouse gas reporting landscape, as well as potential developments ahead, such as the proposed SEC climate risk disclosure rule. For additional information on the voluntary disclosure landscape, see this post.
The Greenhouse Gas Reporting Program (GHGRP)
The Greenhouse Gas Reporting Program, which is typically referred to as the GHGRP, was established in 2009 by the U.S. Environmental Protection Agency (EPA). This federal emissions reporting program requires high-emitting companies to account for and report on greenhouse gas emissions at the facility level. In 2021, over 8,000 facilities across the United States reported annual emissions via the GHGRP.
Under this mandatory federal emissions reporting program, facilities are required to report if they emit over 25,000 metric tons of greenhouse gases (GHGs) per year. Facilities with less than 25,000 metric tons of emissions per year are not impacted by the GHGRP. The GHGs regulated under the GHGRP umbrella include carbon dioxide (CO2), methane (CH4), nitrous oxide (N20), hydrofluorocarbons (HFCs), perfluorinated compounds (PFCs), sulfur hexafluoride (SF6), and other fluorinated gases.
The GHGRP asks companies to categorize emissions by process, including stationary combustion and electricity generation. The EPA currently requests data from facilities that emit GHGs themselves, facilities involved in the production of fuels that will produce significant emissions when combusted, and sites that inject CO2 into the ground.
According to 2021 GHGRP data, 7,608 facilities across nine industries were required to report direct emissions under the GHGRP requirements. In addition, 966 suppliers of fossil fuels and industrial gases and 87 CO2 injection facilities were required to report. These facilities were supervised by ~3,300 parent companies. Many of these parent companies are household names, such as Exxon Mobil, Waste Management, Koch Industries, and the U.S. Government. The top 5 verticals impacted (listed by highest emissions) are power plants, the oil & gas sector, chemicals sector, refineries sector, and waste sector.
It’s important to note that the Greenhouse Gas Reporting Program (GHGRP) is purely a reporting program and does not impose emissions limits or mandate reductions.
An Overview of State Regulations
Beyond the federal EPA greenhouse gas reporting requirements, multiple states have launched their own mandatory requirements for carbon accounting, measurement, and disclosure, including California, Oregon, Washington, with many more state regulations anticipated in the coming years. Each state has its own emissions threshold for data reporting. For example, companies based in California and Washington are required to report if they emit more than 10,000 metric tons per year, which is over 50% more sensitive than the GHGRP threshold. Based on 2021 data, over 350 California-based facilities reported direct emissions to GHGRP, while more than 800 California facilities reported to CARB.
Oregon has an even lower threshold of 2,500 metric tons, but only certain sectors are required to report. For example, air contamination sources and energy suppliers must report, but GHGRP-regulated industries, such as paper & pulp and electronics manufacturing are excluded.
Many companies end up completing multiple emissions disclosure reports annually if they exceed both in-state and EPA thresholds. The three states with separate emissions reporting standards all have more stringent requirements than the GHGRP, so the number of companies impacted by and reporting to those state regulations is much greater.
Currently, there are no city-specific greenhouse gas reporting requirements, although many municipalities have other forms of emissions reduction targets relevant to specific sectors (such as Local Law 97 in New York City).
Cap-and-trade programs, such as the East Coast’s RGGI, offer both environmental and economic incentives to limit emissions and are sometimes confused with regulatory bodies. While they are not a reporting-based regulatory program, like CARB or GHGRP, they do require facility-level emissions measurement and enforce emissions reduction targets through decarbonization.
Looking Ahead: New Reporting Requirements on the Horizon
In the first half of 2022, the US Security and Exchange Commission (SEC) released proposals for two new rules that would vastly expand the scope of private-sector climate disclosure regulation.
One rule, proposed in March, would require US publicly traded companies and international companies listed on US exchanges to include information on climate-related risks and GHG emissions along with their financial filings. The proposed rule would require Scope 1 and 2 emissions reporting, with audit requirements ramping up over the next couple of years. Scope 3 reporting would only be required in disclosures if they are material or related to a target of the filing company. Public companies would also be required to disclose any specific ESG impact, such as a net-zero plan, that they seek to achieve. The proposed disclosure rule is intended to allow investors to make more educated decisions based on verified ESG and emissions metrics, avoiding confusing situations where company reports are not “apples to apples” across the board. The SEC is expected to finalize the rule before the end of 2022.
Then in May, the SEC proposed another rule that would enact greater enforcement of ESG reporting by requiring further clarity and transparency around ESG marketing and communication norms for investors. This proposal is intended to protect investors by setting a standard for investment advisors and investment companies marketing themselves as “ESG focused,” which includes uniform data requirements.
For public companies, these rules would represent a major shift in the climate-related regulatory landscape – going from zero federally-mandated disclosure requirements for many companies to regulated disclosure of emissions and other information.
Looking Ahead: Proposed EPA and GHGRP Rule Changes
The EPA has also announced proposed rule changes that may result in new data requirements to improve quality and streamline calculation methods, as well as potentially expand the GHGRP to include new categories. This change is intended to increase efficiency and clarity, but may require additional data requests and internal adjustments for GHGRP companies to adhere to the updated standards. Revisions would also include direct air capture as a carbon capture option and add a subpart for an additional geologic sequestration method.
Additionally, President Biden proposed additional methane emissions restrictions at the COP27 United Nations Climate Conference on November 11th, 2022. This supplements the EPA’s earlier November proposal and signals additional regulatory pressures to come.
What's Next?
GHGRP reports are due March 31st of each calendar year. If your company has facilities that exceed the GHGRP threshold, your cumulative 2022 data will be necessary to calculate your emissions. To learn more about how technology can streamline the greenhouse gas reporting process and save your team time and money, reach out to our team. Gravity enables businesses to gain valuable insights necessary to navigate this environment with accuracy and transparency.