U.S. Greenhouse Gas Reporting Risk & the Future of Accountability
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February 26, 2026 in Inside the Institute by Keri Enright-Kato

With U.S. Greenhouse Gas Reporting at Risk, Who Protects Climate Accountability?

The US capital building sits behind a fountain.“Remember when…..?”

It’s a phrase used when looking back, often fondly, on moments that mattered. So let’s go back in time a bit. Remember when addressing climate change in the United States was rooted more in science than partisan ideology? When acknowledging climate risk and tracking greenhouse gas (GHG) emissions was more of a shared responsibility that demanded a collective solution?

While perhaps distant in our memory now, there was a time when U.S. climate policy received bipartisan cooperation and relied on technical expertise. That spirit has faded, and unlike many peer countries where climate change policy remains comparatively less polarized, the U.S. now faces policy instability, reversals, and growing uncertainty around the institutions that support climate governance.

The politicization of climate change in the U.S. has left lasting damage. The latest blow came this past September, when the U.S. Environmental Protection Agency (EPA) proposed to eliminate reporting requirements for 46 source categories of facilities under the Greenhouse Gas Reporting Program (GHGRP), pursuant to President Trump’s Executive Order 14192, “Unleashing Prosperity through Deregulation.” Let’s be clear, this is not deregulation for the sake of efficiency; it is a direct attack on yet another foundational program that enables the implementation of climate policy, both now and into the future. By dismantling the systems that generate credible, standardized emissions data, the U.S. government is weakening its own capacity to manage GHG emissions, even if future political leadership wished to do so.

While transparency is certainly part of what is being lost, the deeper harm is the intentional dismantling of the government’s ability to act. Without reliable emissions data, the U.S. loses the ability to regulate, plan, or even evaluate its own policy choices. This institutional damage will persist long after any single administration has left office. This raises a fundamental question for those in the U.S. working on climate change: When national climate institutions are intentionally weakened, where does responsibility for preserving emissions data and accountability reside, and how can effective climate governance continue?

A bipartisan foundation for accountability

Before we answer this question, it’s important to take a closer look at the U.S. GHGRP and why dismantling it is so harmful. The GHGRP has been one of the real success stories in U.S. climate governance, producing the nation’s most comprehensive and credible database of GHG emissions. Established with bipartisan and industry support, it was created to ensure accurate, facility-level reporting of GHG emissions and to provide comprehensive, trustworthy, and publicly available GHG data.

Its roots go back to the FY2008 Consolidated Appropriations Act, which provided $4.5 million for the EPA to develop a mandatory GHG reporting rule. The legislation was passed with broad bipartisan support from roughly two-thirds of the House and nearly 90 percent of the Senate. And on December 26, 2007, it was signed into law by Republican President George W. Bush.

Under the program, large industrial facilities emitting more than 25,000 metric tons of CO₂ equivalent per year, along with CO₂ injection sites and suppliers of fossil fuels and industrial high-GWP 1 gases, are required to report their emissions annually. For more than a decade, thousands of facilities have submitted consistent emissions data every year, creating a record of emissions from major sources across the U.S. economy.

The GHGRP is not regulatory red tape designed to constrain industry. It provides bottom-up, facility-level data that shows where emissions occur and how they vary over time and across sectors and sources. The program complements the U.S. national GHG inventory process, helping to strengthen and contextualize national estimates by supplying annual facility emissions, activity data, and emission factors that help refine national estimates and trends over time.

Beyond its role in supporting national policy analysis, GHGRP data also offers a wide range of practical uses. Companies can use the information to identify potential opportunities for emissions reduction, while communities gain visibility into local sources of emissions. State and local policymakers also rely on data to compare emissions across facilities and industries, track changes over time, and inform state and local climate policies. The dataset also supports financial and investment decision-making by providing consistent, comparable emissions information.2

Over the program’s history, the GHGRP has provided a transparent, standardized record that companies, regulators, and investors have been able to rely on regardless of political affiliation. It’s the kind of quiet policy infrastructure that enables informed decision-making without prescribing outcomes. Dismantling the GHGRP does more than remove a reporting requirement; it dismantles a rare example of bipartisan, institutional capacity in U.S. climate governance. Once that foundation is gone, rebuilding the technical systems, regulatory norms, and trust in government climate programs will be far more difficult.

When the U.S. national government retreats, states can step up—this moment is no different

Over the past 18 years, the U.S. national government’s wavering leadership on climate change has created a “yo-yo” effect, with progress under one presidential administration followed by regression under another. The EPA’s proposed rollback of the GHGRP continues this pattern, leaving the country once again without clear national leadership and adding uncertainty about the institutions meant to support it.

As the national government retreats, states should act, not as a backup, but as the backbone of national climate accountability. This is possible in a federal system like that of the United States. When the national government chooses not to act on an issue, individual states retain both the legal authority and ability to step up. This division of powers is a core feature of U.S. federalism, designed to enhance accountability among elected officials and to enable states to test and refine innovative policy approaches within their own jurisdictions.

Using this state power, some state governments are acting to ensure that emission tracking and climate accountability do not collapse with national rollbacks. These states have embedded GHG reporting into state law, creating a durable system that supports policy design, regulatory oversight, and long-term planning. These programs match, and even exceed, the rigor of the national GHGRP for facilities within their state.

These state-level reporting programs currently include:

While these state mandatory reporting programs share the common goal of ensuring access to credible, facility-level GHG emissions data, they’re not identical to the national GHGRP or to one another. Each state has tailored its regulations and reporting requirements to align with specific policy objectives, state legal authority, and the ability to administer, oversee, and enforce the program.

For example, one way they vary is with reporting thresholds. California3, Washington4, and New York’s5 (proposed) programs require reporting from facilities that annually emit 10,000 metric tons of CO₂e or more, while Oregon6 primarily uses a 2,500 metric ton threshold. Massachusetts falls in between, requiring facilities emitting ≥5,000 short tons of CO₂e per year (~4,536 metric tons).7 Each of these approaches captures a wider range of sources than the national GHGRP.

Verification and auditing requirements further distinguish state programs from the national GHGRP, which doesn’t require third-party verification or auditing. California requires independent third-party verification by a California Air Resource Board accredited verifier. 8 This is a core element of its reporting system, reinforcing data credibility for compliance and enforcement purposes. Oregon’s verification requirements vary by source: large facilities and suppliers must verify ≥25,000 metric tons of CO₂e, while electricity suppliers must undergo verification regardless of emissions.9 Washington includes verification provisions aligned with its cap-and-invest framework, and, similar to Oregon, third-party verification is required for entities that report ≥25,000 metric tons of CO₂e.10 Massachusetts relies more heavily on agency review rather than formal third-party verification, reflecting its emphasis on emissions tracking and policy analysis. These differences highlight how states tailor their verification and auditing practices to balance data accuracy, regulatory oversight, and program goals, thereby making reporting requirements more robust than those of the national GHGRP.

Lastly, unlike the GHGRP, which primarily serves as a data-collection program, many state reporting systems are directly integrated into enforceable climate policies. California and Washington use reported emissions data to support their cap and invest programs, where emissions reporting informs compliance determinations, allowance allocation, and enforcement. Massachusetts relies on reporting data to support statutory emissions reduction targets, regulatory planning, and program evaluation. New York’s proposed program, while not imposing direct emission-reduction requirements, will use facility-level reporting to support the state’s annual GHG emissions report and to establish a baseline for future regulatory and policy actions, positioning emissions data as a foundation for subsequent climate governance.

Together, these state programs show that mandatory emissions reporting can be adapted to different legal authorities, policy goals, and administrative capacities while still producing high-quality data. As national reporting requirements are weakened, these state-led models offer other states a practical way to track emissions, design and enforce effective policies, give regulated entities clearer expectations, and ensure that emissions accountability remains at the forefront of U.S. climate governance.

What is at stake and what can be done?

The GHGRP was built on the belief that you cannot manage what you do not measure. That principle remains as true today as it was in 2008. Weakening national emissions reporting will have significant consequences that extend well beyond the current administration.

Rolling back reporting under the GHGRP program will undermine accountability for industries and sectors with significant emissions. Reporting ensures that major emitters are subject to consistent measurement and public disclosure, creating a basis for regulatory oversight, market evaluation, and informed decision-making. Without standardized public reporting, emissions become less visible, comparisons across facilities and sectors become more difficult, and it becomes harder for regulators, investors, and communities to assess performance or verify claims. Over time, this erosion of accountability reduces incentives for emissions management and undermines confidence in both voluntary and regulatory approaches to climate action.

Diminished reporting also makes it harder to plan effectively. Reliable, long-term, facility-level data is needed to track trends, identify major emitters, and assess policy outcomes. Over time, gaps in emissions data undermine our ability to plan ahead, significantly impacting decisions that carry long-time horizons.

Finally, the erosion of the GHGRP also carries lasting impacts on reporting entities. Companies that have built systems and processes to track and report emissions rely on consistent reporting frameworks to ensure accuracy and comparability. Reliable emissions data systems take years to build, refine, and normalize. Once dismantled, they cannot be quickly or easily reestablished, even if political priorities shift. This disruption will potentially weaken the U.S.’s capacity to credibly engage in future rulemaking or international commitments.

To answer the question posed at the outset of this blog: When national climate institutions are weakened, responsibility for preserving emissions data and accountability does not vanish. The responsibility can instead shift to state governments. By embedding reporting requirements in state law, states can protect access to emissions data and sustain the institutional capacity needed to measure and manage over time.

But isolated action is not enough. A much broader set of states must adopt their own GHG reporting programs to meaningfully fill the gap left by a weakened GHGRP. Fortunately, states do not need to start from scratch. California, Oregon, Massachusetts, Washington, and New York’s (proposed) programs provide practical, tested models for preserving emissions reporting. Adoption by other states would keep emissions tracking more consistent across regions and sectors, make compliance easier for businesses operating in multiple states, and ensure there is reliable data to support sound analysis and decision-making. In doing so, states can help ensure that the institutional capacity to measure and manage emissions stays intact, even when U.S. national leadership falters.

Ultimately, collective action in the United States to address climate change may no longer come from U.S. national leadership, but from a shared commitment by individual states to measure, report, and account for GHG emissions.

  1. Hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), nitrogen trifluoride (NF3), sulfur hexafluoride (SF6), and other gases with high Global Warming Potential (GWP) values.
  2. https://www.epa.gov/ghgreporting/ghgrp-and-us-inventory-greenhouse-gas-emissions-and-sinks
  3. https://ww2.arb.ca.gov/sites/default/files/classic/cc/reporting/ghg-rep/regulation/mrr-2018-unofficial-2019-4-3.pdf
  4. https://ecology.wa.gov/air-climate/reducing-greenhouse-gas-emissions/tracking-greenhouse-gases/mandatory-greenhouse-gas-reports
  5. https://dec.ny.gov/environmental-protection/air-quality/mandatory-greenhouse-gas-reporting
  6. https://secure.sos.state.or.us/oard/viewSingleRule.action?ruleVrsnRsn=307412
  7. https://www.mass.gov/guides/massdep-greenhouse-gas-emissions-reporting-program
  8. https://ww2.arb.ca.gov/verification
  9. https://www.oregon.gov/deq/ghgp/3pv/pages/ghg3partyentities.aspx
  10. https://ecology.wa.gov/air-climate/climate-commitment-act/cap-and-invest/emissions-reporting/third-party-emissions-verification

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