US Climate Disclosure: Stay up to Date with Key Federal & State Regulations for Businesses

The emissions and climate disclosure landscape in US, at both federal and state-level, is rapidly changing. The Trump administration has rejected the UN Sustainable Development Goals, which has called into question the federal government’s support for climate -related disclosures, and broader sustainability initiatives. Several U.S states are developing regulation in anticipation of a regulation gap ...

Anna Twomlow

17 Feb 2026 5 mins read time

The emissions and climate disclosure landscape in US, at both federal and state-level, is rapidly changing. The Trump administration has rejected the UN Sustainable Development Goals, which has called into question the federal government’s support for climate -related disclosures, and broader sustainability initiatives. Several U.S states are developing regulation in anticipation of a regulation gap at the federal level.

SE Advisory Services will be monitoring this changing landscape closely in the US and Canada and providing updates to this page accordingly. Our tailored solutions, including carbon footprinting, target setting, climate scenario analysis and regulatory gap analysis services will help companies navigate these regulations to maximize both compliance and impact.

Federal Regulation in the USA

On April 8, 2025, the President of the United States signed an executive order directing the attorney general to identify state laws addressing climate change, carbon and greenhouse gas emissions, and related issues. The order requires a report outlining potential federal actions against such state legislation, resulting in uncertainty for regulations under development in several U.S. states.

Greenhouse Gas Reporting Program (GHGRP)

Since 2010, approximately 8,000 facilities have reported emissions to the EPA annually. Facilities and suppliers are required to submit GHG emissions reports from covered sources exceeding 25,000 metric tons CO2e per year. These emissions primarily fall under Scope 1. However, given EPA budget cuts and the Trump administration’s push for deregulation, there is uncertainty around future federal disclosure requirements.

State-level Regulation in the US

Enacted Regulations

California – Senate Bill 219 (SB 253)  

California continues to lead the U.S. in climate‑related disclosure laws. SB 253 was enacted in October 2023 and establishes mandatory greenhouse‑gas emissions reporting for large companies operating in the state.

In September 2024, the Legislature passed SB 219, which made targeted updates to support implementation of SB 253 and SB 261—such as extending CARB’s rulemaking deadline and allowing parent‑level reporting—while keeping SB 253’s main requirements and timelines intact.

Key Provisions:

  • SB 253 – Enacted & Active. SB 253 remains fully in effect, as the Ninth Circuit declined to enjoin the law, and implementation is moving forward on schedule.
  • Who must report: Companies with annual revenues over $1 billion that do business in California.
    • Scope 1 & Scope 2 reporting: First disclosure due August 10, 2026
    • Scope 3 reporting: Begins in 2027
  • With SB 253 enacted and active, companies meeting the thresholds should continue preparing now for emissions tracking and reporting.

New York: Senate Bill S9072

Building on California’s model, New York lawmakers have advanced the Climate Corporate Data Accountability Act (CCDAA), which would require large companies doing business in the state to disclose their greenhouse gas emissions. The bill has passed the New York State Senate and now awaits further action in the State Assembly and by the Governor.

Key Provisions:

  • Senate Bill S9072 proposes that companies that meet the below three criteria should publicly report Scope 1, 2 and 3 greenhouse gas emissions in tiered stages beginning in 2028:
    • Entities that have more than $1 billion in annual global revenue, including revenue from all subsidiaries that do business in New York
    • Entity must be “doing business” in New York
    • Entity must also be “deriving receipts from activity in this state”, which occurs when it has $1 million or more in New York‑sourced receipts in a taxable year

Proposed Regulations

California – Senate Bill 219 (SB 261)  

As of November 18th, an injunction halts enforcement of the law requiring companies to report on climate-related financial risks by January 1st, 2026.

  • SB 261Enforcement Temporarily Paused: Enforcement is currently paused following a Ninth Circuit injunction issued on November 18, 2025, which halted the statutory January 1, 2026 deadline while the law is under appeal. CARB has confirmed that it will not enforce that deadline during the injunction period and is expected to set a revised reporting date once litigation is resolved. Companies should maintain readiness for eventual climate-risk reporting but should recognize that SB 261 obligations are paused.

New York: Bill S3697

Two bills were officially introduced by New-York senators in January 2025, as updated versions of bills that failed to pass in the 2021-22 and 2023-24 legislative sessions. These bills are very similar to SB219 in California and are currently in the initial stages of the legislative process, awaiting further action within the committee. S9072 has passed through senate, and S3697 has been referred to environmental conservation.

Key Provisions:

  • Senate Bill S3697 focuses on climate-related financial risk disclosure, proposing that any business entity formed in the US with a total annual revenue exceeding $500 million in its prior fiscal year should prepare a climate-related financial risk report biennially, beginning in 2028.

New Jersey: Bill S4117

New Jersey’s Senate introduced Bill S4117, the Climate Corporate Data Accountability Act in January 2025. As of March 2025, the bill has been referred to Senate Budget and Appropriations Committee

Key Provisions:

  • Bill S4117 would require companies with annual revenues over $1 billion to disclose their Scope 1, 2, and 3 greenhouse gas emissions within four years of the effective legislation date.

Illinois: House Bill 3673

Illinois introduced HB 3673, the Climate Corporate Accountability Act in March 2025. The bill has been re-referred to Rules committee.

Key Provisions:

  • HB 3673 would require companies with annual revenues over $1 billion, and that do business in Illinois, to disclose their Scope 1, 2, and 3 greenhouse gas emissions in tiered stages beginning in 2027.

States to watch

Emissions and climate disclosure bills were proposed in the Colorado, Illinois, Minnesota and Washington senates in the last few years. Whilst these proposals were unsuccessful, updated versions of the bills are expected to in the near future.

Stay Up to Date

Regulatory frameworks for emissions and climate risk disclosure in US are evolving quickly, with new standards and updates expected in the coming months and years at both federal and state levels. SE Advisory Services remains committed to keeping businesses informed as these changes unfold. We will continue to update this page with the latest developments, ensuring you have the insights needed to stay ahead.

For tailored guidance on regulatory compliance and strategic climate action, reach out to SE Advisory Services. Stay tuned for future updates as we track the US’s progress in emissions and climate risk disclosure.