New York is following in California’s footsteps with the introduction of the Climate Corporate Data Accountability Act (CCDAA). Formally introduced as Senate Bill S3456, the legislation has been referred to the Senate Environmental Conservation Committee for further deliberation. It is sponsored by Senator Brad Hoylman-Sigal, with co-sponsorship from Senators Andrew Gounardes, Peter Harckham, Robert Jackson, Rachel May, and Jessica Ramos. A companion bill, A4282, has been introduced in New York’s Assembly.
This proposed legislation 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 would 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 or 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
Introduced in January 2025 by Senator Hoylman-Sigal, the CCDAA seeks to enhance corporate climate transparency and establish a centralized emissions reporting system in New York. The bill mandates that businesses annually 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 legislation 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.
How It Compares to California’s SB 253
While similar to California’s Climate Corporate Data Accountability Act (SB 253), New York’s CCDAA differs in some of its details:
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New York’s bill aligns closely with California’s framework, potentially heralding a national trend towards mandatory climate disclosures by states.
Why It Matters
If passed, 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.
What’s Next? Preparing for Compliance
If enacted, the CCDAA would take effect starting in 2027 with companies reporting on their 2026 emissions data. 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 Pro’s free carbon accounting platform with value chain partners to facilitate data exchange and communication.
- Stay abreast of updates to the bill and 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.
Learn how Persefoni Consulting Group can help you manage disclosures and develop a strong climate program.
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 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 2028 based on 2027 data, with potential third-party assurance requirements by 2031.
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.
