Alert
Corporate Climate Disclosure May Be Coming to New York—Are You Prepared?
New York may soon join the growing list of jurisdictions requiring corporate climate disclosures.
The New York State Senate passed the Climate Corporate Data Accountability Act (S9072A) in February 2026. The bill is a proposal that would require certain large companies doing business in New York to publicly report their greenhouse gas emissions.
Who Would Be Affected by New York Climate Regulation?
Companies with over $1 billion in annual revenue that generate receipts tied to New York activity.
What Would Be Disclosed in New NY GHG Reporting?
Annual emissions reporting aligned with the Greenhouse Gas (GHG) Protocol, including:
- Scope 1—direct operational emissions
- Scope 2—emissions from purchased electricity/energy
- Scope 3—emissions across the value chain
Potential Timing of New York Climate Regulation
- State regulators would issue rules by Dec 31, 2027
- Scope 1 and 2 reporting expected to begin in 2028 based on 2027 data
- Scope 3 reporting expected in 2029
- Independent third-party assurance required; Scope 1 and 2 begin with limited assurance in 2028, transitioning to reasonable assurance by 2032
The bill also includes phased assurance requirements and good-faith protections for Scope 3 estimates, acknowledging the challenges of value-chain data.
ESG Regulation Considerations
With climate disclosure regimes emerging across multiple states including SB 253 in California, companies may want to start thinking about data systems, governance, and reporting alignment across jurisdictions.
What’s Next
The legislation now moves to the New York Assembly, where the next stage of the process will unfold.
We’re Here to Help
For help preparing for climate disclosure requirements, contact your firm professional.