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National Law Review
National Law Review
7/10/2026
With Federal Greenhouse Gas Reporting in Limbo, States Expand GHG Reporting

With Federal Greenhouse Gas Reporting in Limbo, States Expand GHG Reporting

Short summary

The EPA's proposed federal Greenhouse Gas Reporting Program repeal remains uncertain, with a decision expected by October 2026. States including California, New York, and others are implementing stronger GHG reporting requirements, including enterprise-level climate financial risk disclosure for companies over $1B revenue. Companies operating in these states must track both federal uncertainty and state-mandated compliance obligations.

  • EPA's federal GHGRP repeal remains in limbo; final decision expected by October 2026
  • States are implementing mandatory GHG reporting and climate financial disclosure programs, particularly California's SB 253 and SB 261
  • Companies need to comply with state-level requirements while federal landscape remains uncertain

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