Climate disclosures 17 Feb 2026
US Climate Disclosure: Stay up to Date with Key Federal & State Regulations for Businesses
5 Min Reading Time
New York is taking a major step toward corporate climate disclosure with the advancement of the Climate Corporate Data Accountability Act (S9072A/A4282-A). This legislation would require large companies doing business in the state to publicly disclose their greenhouse gas (GHG) emissions.
The New York climate disclosure bill passed the New York Senate on February 10, 2026, and is now under review by the Assembly, so is not yet in effect. If enacted, it would establish one of the most comprehensive state-level emissions reporting programs in the U.S., aligned with widely used greenhouse gas accounting standards such as the GHG Protocol and similar initiatives in California and international markets.
This bill signals a continued shift toward mandatory, high‑quality emissions reporting across jurisdictions. As companies prepare for increasingly standardized and data‑driven disclosure expectations, organizations will have to navigate the implications of NY S9072A, strengthen reporting readiness, enhance emissions transparency, and navigate environmental disclosures that become inseparable from corporate accountability and regulatory compliance.
Below is a breakdown of what the proposed law means for businesses and what actions companies should consider now.
The bill applies only to companies that meet all three of the following thresholds:
Companies must have more than $1 billion in annual global revenue, including revenue from subsidiaries conducting business in New York.
An entity is considered to be doing business in New York if it engages in activities such as:
This includes revenue linked to New York customers or activities located within the state, determined the same way as New York corporate franchise tax calculations.
Entities not considered to be “doing business” in New York, such as those whose in‑state presence falls entirely within narrow safe-harbor rules (e.g., holding board meetings, maintaining a bank account), are exempt.
Subsidiaries included in a parent company’s consolidated financials may rely on the parent to report on their behalf.
Beginning in 2028, covered entities must publicly report their Scope 1 and Scope 2 emissions annually. All emissions must be calculated using the GHG Protocol Corporate Accounting and Reporting Standard.
Starting in 2029, companies must also report Scope 3 emissions, following a schedule and methodology to be outlined by the New York Department of Environmental Conservation (DEC). All emissions must be calculated using GHG Protocol Corporate Value Chain (Scope 3) Standard.
DEC will issue further guidance on acceptable data sources and data-quality tiers for Scope 3.
The DEC will create or contract with an emissions reporting organization to build and manage a public digital reporting platform. Specific reporting deadlines in 2028 will be set through future rulemaking.
New York will allow companies to submit emissions reports that were already prepared for other frameworks, such as California’s SB 253 or ISSB/IFRS, if they meet New York’s requirements.
To strengthen data credibility, the Act includes phased assurance requirements:
Scope 1 & 2
Scope 3
Entities must pay annual administrative fees to support program costs (amounts to be set by the DEC over undetermined timeline).
| Year | Milestone |
| 2027 | DEC finalizes regulatory framework by December 31 |
| 2028 | Scope 1 & 2 public reporting begins (limited assurance) |
| 2029 | Scope 3 public reporting begins (penalties for non-filing only) |
| 2032 | Reasonable assurance required for Scope 1 & 2; DEC may set Scope 3 assurance requirements |
| 2035 | DEC may adopt alternative global reporting standards |
Even before the law is enacted, organizations with operations or revenue exposure in New York should begin building the foundations for compliance. The companies that move early will face lower transition risks, and greater operational resilience as disclosure requirements accelerate across jurisdictions. For most organizations starting from scratch, developing a GHG inventory may take two to four months, with another two to three months required to ready it for assurance. Adding Scope 3 can add another four to six months, depending on data availability, organizational complexity and coordination across teams. In practice, many organizations spend their first year building the systems and processes needed for a complete, assurance-ready inventory.
Evaluate your current emissions data landscape across Scope 1, Scope 2, and Scope 3. This should include:
Develop emissions inventories that are assurance‑ready:
Given the law’s phased Scope 3 timetable, companies should begin enhancing their approach now:
The bill introduces staged assurance levels, moving from limited to reasonable assurance over time. Companies should:
New York’s Climate Corporate Data Accountability Act represents a growing trend. The message is clear – states and international regulators are demanding greater transparency around corporate emissions.
In the United States, California has already enacted SB 253, requiring companies with over $1 billion in annual revenue doing business in the state to report Scope 1, Scope 2, and Scope 3 greenhouse gas emissions aligned with Greenhouse Gas Protocol calculation methods beginning in 2026. Internationally, the IFRS Sustainability Disclosure Standards (IFRS S1 and S2) establish a global baseline for consistent, investor‑focused reporting on sustainability and climate‑related risks, building on the TCFD framework to enhance comparability across markets. In parallel, the European Union’s Corporate Sustainability Reporting Directive (CSRD) is expanding mandatory sustainability reporting across thousands of companies operating in the EU, requiring disclosures under the European Sustainability Reporting Standards (ESRS), with phase 1 companies starting with fiscal year 2024 reports published in 2025.
If enacted, New York’s legislation would position the state as a leading regulatory jurisdiction, advancing the drive toward unified, decision‑useful climate disclosures and increasing expectations for corporate accountability across the economy.
Our Big eBook of Sustainability Reporting Frameworks catalogues the major mandatory and voluntary frameworks, standards, methodologies and permits for businesses. It includes a summary of who reports, what is required and the benefits of each framework.
This is your go-to guide for environmental reporting.
Choose SE Advisory Services for industry-leading expertise in climate strategy and sustainability solutions. We’re here to guide your business through every step towards achieving your sustainability goals while supporting your operational success and market reputation.