Overview of SB 3697
Introduced: January 2025 (currently in Senate committee)
Effective from: First report due January 1, 2028
Last modified: N/A (pending legislation)
Region(s): New York, United States
About SB 3697
New York SB 3697 Climate-Related Financial Risk Disclosure Act would establish mandatory climate risk disclosure reporting for companies with significant operations in the state.
A companion to SB 3456, this bill requires large entities to submit biennial public reports in line with the Task Force on Climate-related Financial Disclosures (TCFD).
These reports must assess material climate-related financial risks, describe governance oversight, and outline risk mitigation strategies—creating transparency for investors, regulators, and the public.
Criteria for compliance
Public and private companies with over US $500 million in global annual revenue and entities “doing business” in New York, regardless of headquarters location.
Compliance timeline (proposed)
- January 1, 2028: First Climate Risk Report due (covering CY 2027)
- Biennial cadence thereafter: Reports due every two years (e.g., 2030, 2032, etc.)
Disclosure requirements
Companies must publish a TCFD-aligned narrative report addressing:
- Governance: Board oversight and management responsibilities for climate risk
- Strategy: Business impacts under short-, medium-, and long-term climate scenarios
- Risk Management: Processes for identifying, assessing, and managing climate-related risks
- Metrics & Targets: Quantitative disclosures of material climate risks, including emissions and financial exposure where relevant
Reports must be posted publicly (e.g., company website) and updated every two years.
Key obligations
- Conduct a comprehensive materiality assessment of climate-related financial risks
- Prepare and publicly disclose a TCFD-compliant report every two years
- Include explanation of mitigation strategies and governance practices
Third-party assurance
Not required, but companies must clearly state whether an external review or independent assurance of their climate risk disclosure was obtained.
Penalties for non-compliance
Administrative fines up to $50,000 per year for failing to publish or for materially incomplete/inadequate disclosures. Additional reputational risks and increased regulatory scrutiny for non-filers.
