New York’s New Climate Reporting Rules — Why Accurate Carbon Data Is Becoming a Compliance Requirement

With the SEC's climate disclosure rule stalled and the EPA proposing to roll back its federal Greenhouse Gas Reporting Program, New York is not waiting.

On February 10, 2026, the New York Senate passed Senate Bill S9072A — the Climate Corporate Data Accountability Act — by a 40–22 vote. The vote fell along party lines, with Democrats in favor and Republicans opposed. The bill has moved to the New York Assembly Codes Committee, where a companion bill, A4282, has also been introduced.

For manufacturers operating in New York, this is not a future concern. It is a present one.

The Climate Corporate Data Accountability Act would require large businesses operating in New York to publicly disclose their greenhouse gas emissions, including Scope 1, 2, and 3. It applies to public and private businesses formed under the laws of the United States, any state, or the District of Columbia, with more than $1 billion in total annual revenue, that conduct business in New York.

The bill, sponsored by Senator Pete Harckham, would protect against greenwashing by requiring businesses with a yearly revenue above $1 billion to annually disclose their direct and indirect greenhouse gas emissions.

The law goes well beyond requiring a number on a page. To enhance reliability and credibility, it also mandates third-party assurance over emissions data. A public emissions reporting platform is planned where companies' disclosures will be easily accessible to investors, regulators, and consumers.

Non-compliance carries serious financial consequences. The penalty structure includes fines of up to $100,000 per day, reaching up to $500,000 per reporting year for companies that willfully fail to comply. The bill also establishes the Climate Accountability and Emissions Disclosure Fund, financed by annual company fees to support administration and enforcement of the law.

The timelines under S9072A are tighter than they appear at first glance.

Under the current bill, companies must publicly disclose their Scope 1 and Scope 2 emissions for the prior fiscal year starting in 2028, and Scope 3 emissions starting in 2029. Implementation regulations from the New York Department of Environmental Conservation (NYDEC) are due December 31, 2027, and the public digital reporting platform is scheduled to be operational by July 1, 2028.

Scope 1 and Scope 2 reporting starting in 2028 will cover data from the 2027 fiscal year — meaning companies should already be tracking this information now. Scope 3 reporting kicks in one year later. Because supply chain data is notoriously difficult to pin down, the bill provides an extra year to get these systems in order.

By 2032, the standard for Scope 1 and Scope 2 verification will rise to reasonable assurance — the same high bar used for financial audits.

On top of the CCDAA, New York has also finalized a separate facility-level reporting program. The New York Department of Environmental Conservation adopted a statewide Mandatory Greenhouse Gas Reporting Program requiring facilities emitting 10,000 metric tons or more of carbon dioxide equivalent per year to report emissions annually, with initial emissions data for calendar year 2026 due June 1, 2027. Certain entities are required to submit an Emissions Monitoring and Measurement Plan by September 1, 2026.

This means manufacturers in New York face obligations on two parallel tracks — one at the facility level and one at the corporate entity level — both converging in 2026 and 2027.

Every sector covered by the CCDAA will feel its weight, but manufacturers face a particularly steep challenge — and it comes down to Scope 3

Scope 3 emissions often represent the largest portion of a manufacturer's total carbon footprint — frequently exceeding direct operational emissions — according to GHG Protocol guidance. They remain difficult to track.

Unlike New York's existing greenhouse gas reporting program, which applies at the facility level, the CCDAA has a broader, corporate-level focus — mandating that large businesses with over $1 billion in revenue operating in New York disclose their full annual GHG inventories, including Scope 3 emissions, which encompass upstream and downstream activities such as suppliers and customers.

This is a fundamental shift. Carbon data is no longer just an environmental operations function. It becomes a company-wide accountability matter that touches procurement, finance, legal, and the entire supplier network.

With regulations like New York's CCDAA now advancing, businesses must track not just their direct Scope 1 and energy-related Scope 2 emissions, but also the vast network of indirect Scope 3 emissions spanning suppliers, logistics, and product end-of-life impacts.

Third-party assurance raises the stakes for data quality even further. Under S9072A, companies must follow the GHG Protocol — the global standard for carbon accounting — to report across all three scopes. Instead of companies picking and choosing what to disclose, the bill mandates a full accounting based on this globally recognized standard, making it possible to compare one organization to another.

New York's law did not emerge in isolation. The CCDAA is heavily modeled on California's GHG disclosure law, which similarly requires companies exceeding $1 billion in revenue operating in California to disclose their emissions.

A provision in New York's proposal aims to minimize duplication of effort, allowing organizations to submit reports prepared for other jurisdictions. For companies already preparing for California's SB 253, much of that compliance work can be structured to meet New York's requirements simultaneously. However, some organizations may be subject to both programs, increasing the need for coordinated reporting systems.

There is also a safe harbor built into the bill for Scope 3. Between 2029 and 2032, Scope 3 penalties are limited to non-filing only, and civil penalties for Scope 3 misstatements are limited, provided disclosures were made with a reasonable basis and in good faith. By January 1, 2029, NYDEC will assess Scope 3 assurance trends and determine assurance requirements. Separately, by January 1, 2032, NYDEC must review and update Scope 3 disclosure deadlines entirely.

New York and California are not isolated cases. New Jersey reintroduced its own Climate Corporate Data Accountability Act in 2026 after a prior version failed, and in Illinois, lawmakers introduced multiple bills requiring climate-related financial risk reporting or emissions disclosures from large companies, with at least one advancing past introduction.

With two of the U.S.'s biggest economies now requiring climate disclosures, other states may follow suit. Until recently, the expectation was that the SEC's proposed climate disclosure rule would establish federal mandatory reporting standards. Now it is clear that states will lead the charge.

The direction of travel is clear. Mandatory, verified corporate climate reporting is expanding across U.S. jurisdictions regardless of what happens at the federal level.

Given the timeline, waiting for the Assembly to pass the final bill before acting is not a viable strategy. The steps manufacturers should prioritize immediately are:

New York's Climate Corporate Data Accountability Act marks a clear turning point. The era of voluntary, estimate-based climate disclosure is giving way to mandatory, publicly accessible reporting — backed by third-party assurance, enforceable penalties, and the full weight of the GHG Protocol standard.

New York is no longer asking for climate data. It is mandating it. If your annual revenue exceeds $1 billion, your emissions data is about to become as scrutinized as your financial statements.

The manufacturers who begin building accurate, GHG Protocol-aligned carbon data infrastructure in 2026 will be positioned to meet reporting deadlines with confidence. Those who wait risk scrambling — and paying for it.

New York manufacturers now face obligations on two distinct but converging tracks. The facility-level Mandatory GHG Reporting Program demands emissions monitoring plans by September 2026 and first data reports by June 2027. The CCDAA, if signed into law, layers a corporate-wide Scope 1, 2, and 3 disclosure requirement on top of that — backed by third-party assurance, public reporting, and civil penalties enforced by the Attorney General.

These are not abstract future concerns. The data that will underpin 2028 Scope 1 and Scope 2 disclosures is being generated right now, in 2026 operations. Manufacturers who treat this year as a data-building year — mapping emissions boundaries, engaging suppliers, and aligning with the GHG Protocol — will be positioned to meet both deadlines without disruption. Those who wait for final Assembly passage before acting will find themselves compressing years of compliance preparation into months.

State-level climate regulation is no longer a regional issue. With New York and California both advancing mandatory disclosure frameworks that mirror each other, and New Jersey and Illinois moving in the same direction, the trajectory for U.S. manufacturers is clear. Accurate, verifiable carbon data is no longer a sustainability team concern. It is a business-critical compliance requirement — and 2026 is the year to treat it as one.