2026 EHS reporting season: what is on the horizon?

As 2025 draws to a close, the 2026 reporting season is already on the horizon. Now is the time to get ahead of fast-approaching deadlines by identifying which reports you’re responsible for and what data you’ll need to prepare accurate, timely submissions.

Air emissions reports

Let’s start with state air emissions inventory reports. Most states require permitted sources to submit some type of report detailing actual emissions of air pollutants during the previous calendar year. Each state’s report is unique in terms of content, pollutants reported, de minimis levels, and methods of submittal. In addition, due dates for these reports vary, ranging from late January through July. So, if you have a permitted air emissions source, be sure to check your state requirements and your permit conditions to determine your emissions reporting responsibilities and deadlines.

March is a busy month

Tier II hazardous chemical inventory reports

Although some facilities will be submitting emissions inventory reports in January and February, the first reporting deadline of 2026 for most facilities will be March 1. This is the due date for hazardous chemical inventory, or Tier II, reports. If your facility used or stored any Extremely Hazardous Substance, as listed in 40 CFR 355 Appendix A, in excess of 500 lbs, or the threshold planning quantity, whichever is lower, or you used or stored any other hazardous substance in excess of 10,000 lbs, you are required to submit a Tier II report. The method of submittal varies by state.

Biennial hazardous waste reports

Also due on March 1 are the Hazardous Waste Biennial Reports. Large quantity generators of hazardous waste, as well as treatment, storage, and disposal facilities, must submit these reports to detail the types and quantities of hazardous waste shipped off-site, and the efforts taken to reduce the volume and toxicity of the wastes generated. In addition, some states require annual reports or have developed their own biennial report forms that require additional information, so be sure to check state requirements.

Work-related injuries and illnesses

Most business establishments must record work-related injuries and illnesses throughout the year. On March 2 of each year, certain establishments are required to electronically submit injury and illness information to OSHA via the agency’s Injury Tracking Application. Establishments with 250 or more employees and those in designated high-hazard industries, as listed in Appendix A to Subpart E of 29 CFR 1904, with 20 to 249 employees must submit OSHA Form 300A: Summary of Work-Related Injuries and Illnesses.

In addition, establishments with 100 or more employees in designated industries, as listed in Appendix B to Subpart E of 29 CFR 1904, must electronically submit to OSHA detailed information about each recordable injury and illness entered on their previous calendar year’s OSHA 300 Log of Work-Related Injuries and Illnesses and OSHA 301 Incident Report forms.

Also, keep in mind that from February 1 to April 30 each year, the OSHA Form 300A: Summary of Work-Related Injuries and Illnesses for the previous calendar year must be posted in a prominent location for employees to view.

Greenhouse gas (GHG) emissions reports

March also brings the reporting deadline for GHG emissions, for now. Sources subject to EPA’s Mandatory Greenhouse Gas Reporting regulations under 40 CFR 98 must submit reports of their 2025 GHG emissions by March 31. All reports must be submitted to EPA using the agency’s electronic Greenhouse Gas Reporting Tool, known as E-GGRT.

However, the EPA proposed a rule in September 2025 that would eliminate GHG reporting for most sources as well as extend the March 31 reporting deadline until June 10, 2026. If the EPA is unable to finalize the elimination of GHG reporting before March 31, look for the agency finalize the extension to give itself more time to finalize the elimination of reporting before the reports are due.

As of now, the March 31 deadline is still valid, but keep an eye on the Federal Register because it appears the EPA does not intend to make sources submit GHG reports.

The arrival of July means TRI

Due on July 1, a Toxics Release Inventory (TRI) report is a summary of how a facility disposes or otherwise releases any of approximately 800 listed toxic chemicals, and it also includes information about how facilities manage those chemicals through pollution prevention, recycling, energy recovery, and treatment.

The takeaway: don’t procrastinate

So, as you can tell, 2026 has the potential to be a very busy year if you are subject to many of these reporting requirements. Therefore, it is not too early to get started compiling the data you may need to fulfill all of your applicable reporting obligations.

But please note that the reports discussed do not comprise an exhaustive list of the reports you may be required to submit. As always, check the federal and state regulations applicable to your facility, as well as your permits, to be certain you are satisfying all of your reporting obligations.