National Law Review
7/10/2026

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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