New York SB 3456: Climate Corporate Data Accountability Act

New York SB 3456: Climate Corporate Data Accountability Act: proposed annual scope 1, 2, and 3 emissions disclosure with iso-accredited verification for companies over $1b revenue in new york.

Jurisdiction
us_state
Status
proposed
Category
climate
First deadline
If enacted, final regulations by December 31, 2026; first Scope 1 and 2 report due July 1, 2027 and first Scope 3 report due December 31, 2027.
Who must comply
Would apply to public and private companies with over $1 billion in global annual revenue that do business in New York (including sales, operations, or services), regardless of state of incorporation.
Penalties
Civil penalties up to $100,000 per day for willful failure to file or disclose accurate emissions, plus additional enforcement by the New York Attorney General and reputational risk.

What it is

New York's proposed SB 3456, the Climate Corporate Data Accountability Act, mirrors California's SB 253 by establishing a statewide requirement for large companies to disclose their global greenhouse gas emissions annually. The law would mandate Scope 1, 2, and 3 disclosures aligned with the Greenhouse Gas Protocol and verified by independent, ISO 14064-accredited third parties, with data published to a state-managed online registry. As introduced on January 8, 2025, it remains in committee and is not yet law.

Who must comply

The bill would apply to public and private companies exceeding $1 billion in global annual revenue that conduct business in New York, including through sales, operations, or services, regardless of where they are incorporated or headquartered.

What you must disclose

Covered companies would be required to report their global Scope 1, 2, and 3 greenhouse gas emissions aligned with GHG Protocol standards, obtain independent ISO 14064-accredited third-party verification, and publish the data to a state-managed online registry. Companies could optionally submit their California SB 253 report to fulfill the New York obligation.

Timeline

SB 3456 was introduced on January 8, 2025 and is currently in committee, not yet law. If enacted, final regulations would be adopted and a filing registry established by December 31, 2026.

The first Scope 1 and 2 emissions report would be due July 1, 2027, and the first Scope 3 report by December 31, 2027, with annual reporting thereafter (Scope 1 and 2 by July 1 and Scope 3 by December 31).

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