Organizations with annual greenhouse gas emissions of 25,000 metric tons CO2e or greater, and those that meet certain other requirements, must report under the EPA’s Greenhouse Gas Reporting Program. However, that’s not the only program companies must comply with. Certain states have their own programs that also require organizations to report greenhouse gas emissions, and understanding these obligations in your state is essential to maintain compliance.
California Greenhouse Gas Reporting
California has one of the most comprehensive greenhouse gas reporting frameworks in the US. The Mandatory Greenhouse Gas Reporting Regulation requires large facilities, fuel suppliers, and electricity importers to track and disclose their emissions. Any facility that emits more than 10,000 metric tons of CO2e annually must report, which is a stricter threshold than the EPA’s Greenhouse Gas Reporting Program. Those with emissions above 25,000 metric tons in certain sectors are also subject to the state’s Cap-and-Trade Program.
Most facilities must submit their emissions data by April 10 each year. Electric power entities must also register specified and unspecified sources by February 3. Specified sources must be registered in advance and linked to approved emission factors, while failing to register forces companies to use higher default values.
Reports must undergo independent third-party verification by California Air Resources Board-accredited verifiers. Final verification statements are due for all reports by August 11, including emissions, supplier data, and product data. Organizations must be prepared with details concerning methodologies, transaction-level electricity data, and additional data to withstand detailed auditor review and must maintain records for at least ten years.
In 2023, the California Legislature passed SB 253, the Climate Corporate Data Accountability Act. This new rule requires any U.S.-based entities with more than $1 billion in annual revenue that do business in California to report greenhouse gas emissions annually. Companies will first have to submit Scope 1 and Scope 2 emissions in 2026, covering reporting year 2025. This will be expanded to include Scope 3 emissions in 2027, covering reporting year 2026
Washington Greenhouse Gas Reporting
Washington requires some facilities to submit annual reports under its Mandatory Greenhouse Gas Reports Program. Aligning closely with California’s requirements, facilities, fuel suppliers, and electric power entities must report if they emit 10,000 metric tons of CO₂e or more annually.
Most reporters submit their data by March 31, while electric power entities have a later deadline of June 1. Organizations must register with the Washington Department of Ecology at least 60 days in advance of reporting deadlines to ensure compliance.
Washington also requires third-party verification for certain reporters, particularly those subject to the state’s Cap-and-Invest Program. Annual reporting fees are also applied, which vary by reporter type. Records must be retained for at least seven years.
Oregon Greenhouse Gas Reporting
Oregon’s Greenhouse Gas Reporting Program has significantly stricter thresholds than the EPA’s Greenhouse Gas Reporting Program. Facilities that emit 2,500 metric tons of CO₂e annually are required to report. In addition, suppliers of fuels such as natural gas, petroleum products, propane, and electricity also have reporting obligations if they meet specified throughput or sales levels.
Reports are due annually by March 31, with certain reporters also subject to third-party verification. Verification applies to larger stationary sources and electricity suppliers, who must engage verifiers approved by the Oregon Department of Environmental Quality within a fixed timeline after submitting their reports.
Electricity data is a particular focus. Reporters must disclose generation data in megawatt hours by facility and fuel type. The Oregon Department of Environmental Quality assigns specific emission factors for registered specified sources, while asset-controlling suppliers are given special system emission factors. Failure to report accurately or on time is considered a major violation, and Oregon enforces reporting fees annually under state law. Reporters must retain records for at least five years.
The Regional Greenhouse Gas Initiative (RGGI)
The Regional Greenhouse Gas Initiative (RGGI) is a cooperative effort among ten states, including Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, New Jersey, New York, Pennsylvania, Rhode Island, and Vermont. The RGGI regulates CO₂ emissions from fossil fuel-fired power plants with a capacity of 25 megawatts or greater. Unlike other programs, the threshold is based on unit capacity rather than annual emissions totals.
The RGGI requires quarterly reports submitted through the CO₂ Allowance Tracking System (COATS). These reports are due 30 days after the end of each quarter and rely on continuous emissions monitoring data.
Compliance is managed through three-year control periods. During each of the first two years, facilities must surrender allowances covering 50 percent of their emissions, followed by a final surrender at the end of the third year. This allows for some flexibility over the period, rather than implementing caps on an annual basis.
The program ties emissions reporting directly to market mechanisms. Each allowance represents one short ton of CO₂, and facilities must purchase allowances at auction or on the secondary market. If a facility fails to surrender enough allowances, it faces steep penalties, including the requirement to surrender three allowances for every ton of excess emissions. Records of emissions, allowance transactions, and monitoring data must be kept for a minimum of three years, ensuring that compliance can be audited at any point in the cycle.
Meeting Your State GHG Reporting Requirements
Accurate greenhouse gas reporting requires understanding the specific requirements in your state. Today, California, Washington, Oregon, and the states included in the RGGI all impose unique requirements. Other states are considering implementing similar programs. New York has proposed a draft regulation to establish a greenhouse gas reporting program. Illinois, Colorado, and New Jersey are also currently exploring similar options.
These programs require complete and accurate data that has been collected and calculated using appropriate and well-documented methods. Keeping up with these requirements through manual tracking and spreadsheets opens the door to oversights and errors that can impact your compliance.
Instead, you can turn to ERA’s Corporate Sustainability Software. You can centralize all of your greenhouse gas emissions data in a single platform, using both standard and customizable metrics to capture Scope 1, 2, and 3 emissions in full detail. ERA’s solution provides comprehensive coverage of every step required for precise GHG reporting.
ERA streamlines the reporting process, making it faster and more efficient. The platform empowers your organization to meet regulatory requirements, adhere to industry-leading standards, and deliver customized reports for internal teams, stakeholders, or public audiences. ERA provides robust tools for emissions monitoring and data management, helping you foster continuous improvement and drive sustainability across your operations.
Ensure that you meet all federal and state greenhouse gas reporting requirements by putting the right solution to work. Schedule a call with one of our project analysts today to find out more about how ERA can support your environmental and sustainability compliance.
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