This policy applies to business that meet the following criteria.

Region

United States (New York)

Industries

Energy and Utilities|||Financial Services|||Healthcare and Pharmaceuticals|||Heavy Manufacturing|||Legal and Professional Services|||Manufacturing|||Oil and Gas|||Retail and Consumer Goods|||Technology and Telecommunications|||Transportation and Logistics|||Waste and Recycling

Revenue

Over $1 billion annually

Assets

N/A

Size

N/A

Status

Proposed (Currently in committee, not yet law)

Required

No (still pending)
Unsure if New York’s SB 3456 could impact your company?

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Overview of SB 3456

Introduced: January 8, 2025
Effective from:Upon enactment; regulations due by December 31, 2026
Last modified: N/A (pending legislation)
Region(s): New York, United States

About SB 3456

New York’s proposed SB 3456 Climate Corporate Data Accountability Act mirrors California’s SB 253, establishing a statewide requirement for large companies to disclose global greenhouse gas (GHG) emissions annually.

The law would mandate Scope 1, 2, and 3 disclosures aligned with the Greenhouse Gas Protocol and verified by independent, ISO-accredited third parties.

SB 3456 represents a coordinated step toward harmonized state-level climate accountability, with provisions for dual compliance to reduce reporting burdens for multistate businesses.

Criteria for compliance

Public and private companies with more than US $1 billion in global annual revenue, and that do business in New York (defined broadly, including sales, operations, or services in the state).

Compliance timeline

  • December 31, 2026: NY Department of Environmental Conservation (DEC) adopts final regulations and establishes filing registry
  • July 1, 2027: First Scope 1 & 2 emissions report due (covering FY 2026)
  • December 31, 2027: First Scope 3 report due (covering FY 2026)
  • Annually thereafter: S1-2 reports by July 1; S3 reports by December 31

Disclosure requirements

Filings must include:

  • Global Scope 1, Scope 2, and Scope 3 GHG emissions
  • Methodology aligned with GHG Protocol Corporate Standard and Scope 3 Standard
  • Third-party verification details and inventory boundary
  • Optional: Companies may submit a copy of their California SB 253 report to fulfill NY obligations
Key obligations
  • Publish annual emissions data to a state-managed online registry
  • Ensure independent verification of data before submission
  • Maintain transparency and accuracy across all Scopes

Third-party assurance

Independent limited assurance required by an ISO 14064-accredited verifier. DEC may transition to reasonable assurance standards in future rulemaking.

Penalties for non-compliance

  • Civil penalties up to $100,000 per day for willful failure to file or disclose accurate emissions
  • Additional enforcement actions by the New York Attorney General
  • Public scrutiny and reputational risk for noncompliance or data misrepresentation
Proposed climate disclosure requirements like NY SB 3456 are coming fast.

Greenplaces helps billion-dollar companies streamline their Scope 1–3 tracking, verification, and reporting—so you’re ready ahead of regulatory deadlines.

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