New York SB 3697: Climate-Related Financial Risk Disclosure Act

New York SB 3697: Climate-Related Financial Risk Disclosure Act: proposed biennial tcfd-aligned climate financial risk report for companies over $500m revenue doing business in new york.

Jurisdiction
us_state
Status
proposed
Category
climate
First deadline
If enacted, first climate risk report due January 1, 2028 (covering CY 2027), then biennially thereafter.
Who must comply
Would apply to public and private companies with over $500 million in global annual revenue that do business in New York, regardless of headquarters location.
Penalties
Administrative fines up to $50,000 per year for failing to publish or for materially incomplete or inadequate disclosures.

What it is

New York's proposed SB 3697, the Climate-Related Financial Risk Disclosure Act, would require large companies doing business in New York to publish reports on their climate-related financial risks and mitigation strategies. The report would follow the TCFD framework, addressing governance, strategy, risk management processes, and quantitative metrics and targets. As introduced in January 2025, it remains in Senate committee and is not yet law.

Who must comply

The bill would apply to public and private companies with over $500 million in global annual revenue that do business in New York, regardless of where they are headquartered.

What you must disclose

Covered companies would be required to publish a TCFD-aligned climate risk report addressing governance, strategy, risk management processes, and quantitative metrics and targets relating to their climate-related financial risks, on a biennial basis.

Timeline

SB 3697 was introduced in January 2025 and is currently in Senate committee, not yet law. If enacted, the first climate-related financial risk report would be due January 1, 2028, covering calendar year 2027.

Reporting would then follow a biennial cadence (2030, 2032, and so on).

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