Mandatory Reporting Requirements for Air Emissions Take Effect in 2026

Companies must prepare to meet expanded EPA reporting obligations under the Inflation Reduction Act, with new mandatory documentation, facility-level data, and attestation audits set to begin in 2026.

• By George Sullivan
• September 09, 2025

Companies preparing to comply with expanded federal air emissions reporting rules will soon face a new layer of documentation under the Mandatory Reporting Requirements (MRR) framework, set to take effect in 2026. The provisions, created under the Inflation Reduction Act of 2022, build on the Clean Air Act and require detailed disclosure of emissions data, organizational policies, facility contacts, and verification procedures.

What the MRR Includes

The MRR functions as a comprehensive record that goes beyond calculating greenhouse gas totals. Companies must provide:

• Policies and accountability: Senior management letters naming primary and secondary contacts responsible for reporting, along with facility-level contacts.
• Organizational structure: Charts and lists of facilities with local, state, and federal reporting obligations.
• Permits and compliance data: Facility-specific air and water permit requirements, Scope 1 fuel usage, flue gas analysis, Scope 1 and 2 equipment efficiencies, and refrigerant management plans.
• Data reporting: Monthly Scope 1 and 2 emissions data, global warming factors, and documentation of calculation methodologies where local or state standards differ from federal ones.
• Verification resources: Attestation officers, ISO 14001 lead auditors, consulting firms, and software platforms used to compile data.

Attestation Audit Requirements

A critical part of the MRR process is the attestation audit, which evaluates the accuracy of a company’s emissions reporting. Audits are conducted by ISO 14001-certified lead auditors and scored on two axes:

• Review level: Limited (20% of data reviewed), Reasonable (50–60%), or Absolute (100%).
• Audit outcome: Positive (no errors), Qualified Positive (errors corrected), or Adverse (uncorrectable errors or unsupported claims).

Reports must follow ISO 14064-3:2018 or newer standards and include Scope 1 and 2 emissions for each facility, including company offices. Improper claims—such as unverified renewable energy credits—could expose companies to regulatory enforcement.

What’s Next

With reporting deadlines approaching, companies should ensure they have the systems, contacts, and audit procedures in place to meet MRR standards. The next phase of guidance will focus on physical and financial risk disclosures under the Task Force on Climate-Related Financial Disclosures (TCFD).