2026 New Refrigerant and Emissions Reporting Requirements: How Facilities Teams Can Prepare

Starting January 1, 2026, major changes to refrigerant management regulations are coming.  The EPA’s AIM Act Subsection H now requires compliance for systems with 15 pounds or more of HFC refrigerant.  That’s a major expansion from previous rules, which only applied to much larger systems. 

Complicating things further, California’s Corporate GHG Disclosure Program adds more requirements. Companies with over $1 billion in revenue must report refrigerant leak emissions across all their locations. At the same time, HFC supplies are being reduced by 85% by 2036. Industry leaders anticipate that this phasedown will drive up costs and create availability issues. 

The stakes are high. EPA fines can reach $60,000 per violation per day, and California penalties for missing or wrong emissions reports can hit $500,000 annually. 

Facilities teams need complete data, reliable vendors, and the right technology (like a reliable refrigerant tracking software) to stay compliant. But they also need coordination across internal compliance stakeholders and external service providers. This is a challenge that requires new approaches to data collection and reporting.

What major policy changes are reshaping HVAC & refrigerant management?

Three policy shifts are changing how facilities teams manage HVAC and refrigeration systems.

Change #1: The AIM Act Subsection H

This new subsection establishes federal rules for equipment with 15 pounds or more of HFC refrigerant with Global Warming Potential over 53. That includes commonly used refrigerants like R-134a, R-32, and components of R-410A blend. The regulation requires leak inspections, repair protocols, and records kept for at least three years. 

Change #2:  California’s Corporate GHG Disclosure Program 

Any public or private company in the US with total revenues over $1 billion that does business in California is required under the CARB program to complete annual emissions reporting, including Scope 1 fugitive emissions from refrigerant leaks. These data are reported in metric tons of CO₂ equivalent. 

Change #3: The HFC Phasedown

The HFC phasedown schedule will eliminate 85% of current supply by 2036, requiring facilities teams to factor refrigerant availability into long-term equipment replacement and maintenance strategies.

Who is impacted, and what systems now fall under regulatory oversight?

The jump from EPA Section 608 to AIM Act Subsection H brings many more systems under federal rules. The old threshold was 50 pounds for ozone-depleting substances; the AIM Act drops this to 15 pounds for HFC systems. 

Systems now requiring regular inspections include:

• Comfort cooling systems with 15+ pounds of qualifying refrigerants
• Commercial refrigeration units meeting the threshold
• Industrial process refrigeration equipment
• Large systems over 1,500 pounds requiring automatic leak detection

Facilities managers must do an asset inventory to determine regulatory exposure based on charge size, refrigerant type, and Global Warming Potential. 

For the CARB Act, businesses don’t need to be located in California to be affected by the rules. Certain sales and property ownership thresholds can trigger an obligation to report. 

Read also: What is a Refrigerant Risk Exposure Assessment And Why You Need One Before 2026

What records and data do facility teams need to collect now?

Full compliance depends on complete, standardized documentation. Unfortunately, most facilities teams don’t currently track data at this level of detail, and outdated CMMS platforms don’t make it easy to do so. 

Required records include:

Leak Inspections

• Date of inspection
• Detection method used
• Leak locations found
• Technician certifications

Leak Repairs

• Appliance details and repair date
• Leak detection method
• Initial and follow-up verification tests
• Refrigerant added or recovered
• Calculated leak rate
• Technician certification

Automatic Leak Detection (for systems over 1,500 pounds)

• Installation date
• Annual calibration date

Retrofit/Retirement Plans

• Location and asset information
• Current charge and refrigerant type
• Planned conversion details
• Leak detection method
• Itemized procedure and timeline
• All leaks repaired status 

Systems that leak 125% or more of full charge annually are considered chronically leaking and must be reported to the EPA by March 1 of the following year. 

California’s reporting adds another layer. Facilities must track installation losses, servicing additions, and disposal losses, then convert these to CO₂ equivalent using each refrigerant’s Global Warming Potential. 

What questions should facilities teams ask their HVAC service providers?

Although many large organizations have a specific role for compliance management, the truth is that compliance planning requires coordination across multiple stakeholders. Facilities teams can’t handle 2026 requirements alone. Instead, they need input from internal compliance teams and external service providers.

Two separate conversations will clarify what data gaps exist and how to address them before the January 1, 2026 deadline.

These two discussions usually identify what data gaps need to be addressed to meet the new compliance standards. Once facilities teams understand what internal compliance needs and what vendors can provide, the path forward becomes clearer.

Questions for your sustainability or compliance team

Internal compliance stakeholders need to understand what facilities data they’ll require for mandatory reporting.

• How will they quantify Scope 1 fugitive emissions from refrigerant leaks for California Air Resource Board (CARB) reporting under SB 253?
• What data from facilities or service vendors do they need to meet federal (AIM Act) and state refrigerant management reporting requirements—including refrigerant type, charge size, and leak history by asset?
• How will mandatory annual reporting of chronically leaking appliances to the EPA be handled?
• What’s the process if one of your facilities gets audited by a regulator? 

Questions for your HVAC service providers

Service providers can be compliance partners or risk points depending on their tracking capabilities. You want your vendors, technicians, and other service providers to be your partners, not potential liabilities. 

Without unified tracking across providers, data fragmentation makes compliance reporting nearly impossible. Be prepared to investigate the following: 

• Can they provide detailed, circuit-level records of refrigerant additions, recoveries, and repairs in a format that meets EPA recordkeeping standards for audits or reporting obligations?
• Do they currently calculate leak rates to flag the 10% and 125% compliance thresholds that trigger additional leak repair, recordkeeping, and reporting obligations? If not, what would they need to do?
• How do they ensure data consistency across all your locations?
• What happens if a different vendor services one of your systems—how does that data integrate?

Enforcement happens through EPA surprise audits, whistle-blower reports from technicians, and compliance reviews automatically triggered by missing filings. Vendors should produce complete documentation on demand, not scramble after an audit notice arrives.

How can facilities teams prepare for audits and meet annual reporting requirements?

Audit readiness means that your data stays unified, complete, and easily exportable across all service providers, locations, and equipment types. The EPA can review records covering the previous three years. 

Preparation steps include:

• Inventory assets to determine regulatory exposure
• Update procedures for new leak inspection and repair requirements
• Calculate, track, and update leak rates for all regulated assets
• Ensure refrigerant management systems maintain audit-ready compliance

Annual inspections continue for systems that exceed leak thresholds until the leak rate stays below 10% for 12 consecutive months. 

How do facilities teams coordinate compliance across departments and vendors?

Because compliance requires so many key players within the organization, facilities teams must orchestrate information flow between internal compliance stakeholders and external service providers. 

Compliance teams need specific data for mandatory reporting. Service providers generate that data during maintenance. Facilities teams bridge the two, ensuring complete information flows from vendors to compliance.

Many facilities teams discover their current systems can’t handle this effectively. Compliance needs data in specific formats for CARB and EPA reporting. Vendors track information inconsistently. Facilities managers lack visibility into what’s documented and what’s missing.

Success requires centralized systems that standardize how refrigerant data gets captured, calculated, and reported, regardless of which vendor performs the work.

What role do modern platforms like Fexa + Trakref play in compliance?

Integrated platforms solve data consolidation and workflow problems that manual systems simply can’t handle. The Fexa CMMS and Trakref native integration synchronizes asset records, work orders, and service events. This creates unified visibility into refrigerant activities. 

Trakref’s regulatory compliance engine continuously adapts to evolving EPA, CARB, and SEC requirements. The platform automatically calculates leak rates, tracks inspection deadlines, and generates one-click reports for regulatory bodies. 

Benefits include:

• Automated refrigerant tracking, which ensures real-time compliance
• Audit-ready reporting generated on demand
• Multi-site management, which consolidates data across locations
• Proactive compliance alerts for upcoming deadlines 

Refrigeration may account for only 10% of work orders, but it represents 90% of financial and regulatory risk. 

Learn more about how Fexa and Trakref can transform your refrigerant compliance strategy by checking out the  Fexa CMMS + Trakref Native Integration.