New York has followed in California’s footsteps with the introduction of the Climate Corporate Data Accountability Act (CCDAA), S9072A. On February 10, 2026, the New York Senate passed the bill (an updated version of S3456), and it moved on to the New York Assembly Codes Committee. A companion bill, A4282, has been introduced in the Assembly.
The Climate Corporate Data Accountability Act would require large businesses operating in New York to publicly disclose their greenhouse gas (GHG) emissions, including scopes 1, 2, and 3. To enhance reliability and credibility, it also mandates third-party assurance over emissions data. If enacted, the CCDAA will set a new standard for emissions accountability on the East Coast.
The bill applies to public and private businesses formed under the laws of the United States, any state, or the District of Columbia, with more than $1B USD in total annual revenue, that conduct business in New York. Like California’s SB 253, the CCDAA aims to standardize corporate emissions reporting, increase transparency, and drive meaningful climate action.
What Happened: New York’s Push for Climate Transparency
The CCDAA was originally introduced in January 2025 by Senator Hoylman-Sigal as S3456. The legislation seeks to establish a centralized emissions reporting system in New York. It mandates that businesses disclose their full carbon inventories, including scope 3 emissions, which often account for the majority of a company’s carbon footprint.
Key components of the policy include:
- Mandatory greenhouse gas emissions disclosure for businesses with over $1B USD in revenue.
- Third-party assurance requirements for reported emissions.
- A public emissions reporting platform where companies’ disclosures will be easily accessible.
- A penalty structure for non-compliance, with fines of up to $100,000 USD per day and reaching up to $500,000 USD per reporting year.
- The creation of the Climate Accountability and Emissions Disclosure Fund, which will be financed by annual company fees to support the administration and enforcement of the law.
The New York Department of Environmental Conservation (NYDEC) would oversee the law’s implementation and manage the newly established Climate Accountability and Emissions Disclosure Fund to support enforcement.
Why It Matters
If signed into law, New York’s CCDAA will further accelerate the adoption of mandatory corporate climate reporting requirements in the US. This signals clear movement by the states to address their climate-related risks.
The legislation:
- Increases transparency: By requiring public disclosure of emissions data, the law will provide investors, regulators, and consumers with better insights into corporate climate performance and climate-related financial risks.
- Encourages better emissions tracking and corporate climate action: With mandatory reporting across scopes 1, 2, and 3, companies will need to establish more robust carbon accounting practices, helping them identify emissions hotspots and areas for improvement.
- Aligns with global disclosure trends: As mentioned above, the bill mirrors emerging climate regulations, including California’s SB 253. A provision in New York’s proposal aims to minimize duplication of effort, allowing organizations to submit reports prepared for other jurisdictions using ISSB standards, which underpin many global disclosure regulations.
Companies already preparing for California’s SB 253 will be better positioned to comply with New York’s CCDAA. Businesses new to mandatory emissions reporting will need to begin developing robust carbon accounting processes to ensure compliance.
Who Does NY CCDAA Apply To?
The updated legislation defines a reporting entity as:
- A partnership, corporation, limited liability company, or other business entity formed under the laws of New York state, the laws of any other state of the United States or the District of Columbia, or under an act of the Congress of the United States that both:
- Does business in New York and derives receipts from activity in New York within the meaning of section 209 of the tax law, and;
- Has total revenues in excess of $1B USD in the preceding fiscal year, including but not limited to revenues received by all of the business entity's subsidiaries that do business in New York.
- A foreign entity shall not be considered to be doing business in New York exclusively by reason of carrying on in the state any of the activities enumerated in subsection (b) of section 1301 of the business corporation law.
- If a reporting entity is included as a consolidated subsidiary in the consolidated financial statements of an ultimate parent entity, then such ultimate parent entity may be the reporting entity for purposes of this definition.
- If a subsidiary of a parent company qualifies as a reporting entity, the subsidiary is not required to prepare a separate report so long as the parent company prepares a report.
Reporting Requirements for CCDAA
Companies must disclose their scope 1 and 2 emissions annually starting in 2028 and their scope 3 emissions starting in 2029 on a schedule to be determined by NYDEC. Disclosures must align with the Greenhouse Gas Protocol Corporate Accounting and Reporting Standards and the Greenhouse Gas Protocol Corporate Value Chain (Scope 3) Accounting and Reporting Standards, and they must be understandable and accessible to the public.
In addition, reports must include third-party assurance, with limited assurance for scope 1 and 2 beginning in 2028 and reasonable assurance beginning in 2032. For scope 3, by January 1, 2029, NYDEC will assess assurance trends and determine assurance requirements. If scope 3 assurance requirements are established, they will be at the limited assurance level beginning in 2032.
The law would allow the AG to seek civil penalties of up to $100,000 per day, capped at $500,000 per reporting year. However, the policy includes a scope 3 safe harbor and limited initial scope 3 penalties: Companies will not be subject to civil action for scope 3 misstatements made with a reasonable basis and disclosed in good faith, and scope 3 penalties between 2029 and 2032 are limited to non-filing only.
Reporting Timeline
The timeline for CCDAA reporting has been updated, with scope 1 and 2 disclosure starting in 2028 and scope 3 disclosure starting in 2029. The bill is set to take effect 180 days after enactment. Implementation regulations from the NYDEC are due December 31, 2027, and the public digital reporting platform is scheduled to be up by July 1, 2028. The NYDEC must review and update scope 3 disclosure deadlines on or before January 1, 2032, and qualifications for third-party assurance providers. Starting in 2035, NYDEC may survey and assess available GHG accounting standards and potentially adopt an alternative globally recognized standard.
NY S9072A Key Dates
- Dec. 31, 2027 - NYDEC regulations due
- 2028 - Scope 1 + 2 disclosure starts; limited assurance required
- July 1, 2028 - Public digital platform up
- 2029 - Scope 3 disclosure starts; NYDEC to determine scope 3 assurance requirements
- 2032 - Reasonable assurance required for scope 1 and 2
What’s Next? Preparing for Compliance
If enacted, the CCDAA will require companies to start reporting their scope 1 and 2 emissions in 2028, based on 2027 data. To prepare, companies should:
- Begin collecting and organizing emissions data in accordance with the GHG Protocol. Businesses should ensure they have the right data infrastructure in place to track emissions across scopes 1, 2, and 3. This may involve implementing or upgrading internal systems, identifying relevant data sources, and establishing clear data collection and reporting processes and controls.
- Engage third-party assurance providers early to streamline verification processes. The CCDAA requires third-party assurance for emissions disclosures, meaning businesses must select and collaborate with assurance providers well in advance. Early engagement will help ensure a smooth verification process and avoid last-minute compliance issues.
- Evaluate scope 3 emissions sources and work with those in their value chains to ensure data integrity. Since scope 3 emissions often make up the largest share of an organization’s footprint, companies must identify key emission sources across their value chain. This requires working closely with suppliers, partners, and vendors to gather accurate emissions data and explore ways to improve data quality and consistency. Reporting companies can share Persefoni's carbon accounting platform with value chain partners to facilitate data exchange and communication.
- Stay abreast of future regulatory updates from NYDEC as reporting guidelines and timelines are finalized. As the bill works its way through the legislature and NYDEC develops regulations and implementation guidelines, businesses will need to stay informed of any changes or clarifications that could affect their reporting obligations. Staying in touch with your Persefoni Climate Solutions Team will be key to ensuring smooth adaptation to the new requirements.
Final Thoughts
New York’s Climate Corporate Data Accountability Act represents another step toward standardized corporate emissions disclosure at the state level. For businesses preparing to comply, having the right tools and team in place is essential. Carbon accounting software can greatly streamline reporting, simplify compliance, and reduce risk. It is the basic building block for a future-proof climate program that will help you stay nimble in the face of emerging and evolving regulations.
Frequently Asked Questions (FAQs)
Q: What does doing business in New York mean, exactly?
According to the bill text, a company may be in scope of the law if it “does business in” New York and derives receipts from activity within the state within the meaning of section 209 of the tax code. NYDEC will need to further define what it means to “do business” in New York in its rulemaking process.
Q: Does the CCDAA apply to private companies?
Yes. Like California’s SB 253, the CCDAA applies to both public and private US businesses with annual revenues over $1B USD that conduct business in New York.
Q: What are the penalties for non-compliance?
Companies failing to comply may face penalties of up to $100,000 USD per day and up to $500,000 USD per year. However, there is a safe harbor provision for scope 3 emissions if reported in good faith.
Q: When do I need to disclose my scope 3 emissions?
Scope 3 emissions disclosure will be required starting in 2029, with potential third-party assurance requirements determined by that time.
Q: How will companies report emissions?
The New York Department of Environmental Conservation (NYDEC) will establish a digital reporting platform where businesses must submit their emissions data for public disclosure.
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