by Bryce Rasmussen | March 6, 2026
As the New York Senate advances Bill S9072A, also known as the Climate Corporate Accountability Act (CCDAA), passed on February 10, 2026, by the New York State Senate, it reinforces a growing reality for corporate climate disclosure in the United States: states are increasingly setting the rules for required sustainability reporting.
New York’s CCDAA is heavily modeled after California’s SB 253, which will require similar disclosures from large corporations. Like its West Coast predecessor, S9072A applies to U.S.-based companies with total annual revenues exceeding $1 billion that do business in the state.
However, New York’s version is notable for its aggressive enforcement provisions. The bill authorizes the Attorney General to bring civil actions against reporting entities for non-compliance, with penalties reaching up to $100,000 per day for willful failure to comply.
- For Scope 3 disclosures, entities will not be subject to civil action for misstatements made with a reasonable basis and in good faith.
- Furthermore, during the initial transition period from 2029 to 2032, penalties related to Scope 3 reporting are strictly limited to non-filing, providing companies with a window to refine their value-chain data collection without the immediate threat of penalties for good-faith errors.
What This Means for Companies Now
Determining applicability requires an analysis of your firm’s activities in New York and, if your entity derives receipts from those activities. If a company falls under this definition, it must prepare for the following phased reporting schedule:
- Reporting Timeline: Disclosures for Scope 1 and Scope 2 emissions will begin in 2028 (based on 2027 data), followed by Scope 3 disclosures in 2029.
- Required Disclosures: If enacted, the legislation would require large companies doing business in New York to publicly disclose their greenhouse gas emissions, aligning the state with a growing group of state jurisdictions pursuing mandatory corporate climate reporting.
- Penalties: Penalties reach up to $100,000 per day for willful failure to comply.
- Assurance Requirements: Reporting entities must obtain independent third-party assurance. For Scope 1 and 2, this begins at a “limited assurance” level in 2028 and transitions to a more stringent “reasonable assurance” in 2032.
- Scope 3 Assurance: The New York Department of Environmental Conservation (DEC) is tasked with reviewing trends in Scope 3 assurance by January 1, 2029, and may establish future requirements starting at a limited assurance level in 2032.
- Public Accountability: By July 1, 2028, a centralized digital platform will be established to feature reporting entities’ emissions data, allowing for public oversight and benchmarking.
Note: A reciprocity provision within CCDAA allows reporting entities to satisfy New York’s requirements by submitting emissions disclosures originally prepared to meet other state, national, or international reporting standards—such as California’s SB 253, federal requirements, or the IFRS Sustainability Disclosure Standards—provided these reports fulfill all statutory criteria of the New York Act.
What’s Next
The momentum behind S9072A is reinforced by a companion bill in the New York Assembly, AB4282. With similar legislation moving through the Assembly, the proposal has gained broader political traction and could move forward if lawmakers continue to align on its final form.
If enacted, the bill would direct the New York Department of Environmental Conservation (DEC) to develop the regulations needed to implement the law by December 31, 2027. That timeline would give companies several years to prepare their emissions reporting systems before disclosure requirements take effect.
New York is not acting in a vacuum. The CCDAA is part of a “growing patchwork” of state-level climate disclosure laws emerging across the country as federal efforts, such as the SEC’s climate disclosure rules, have faced significant retractions. Notably, Illinois has introduced its own version, HB3673, which similarly targets companies with over $1 billion in revenue. States currently pursuing or implementing these laws, including New York and Illinois, as well as California, Colorado, and New Jersey, represent a significant portion of the U.S. economy. For a multinational corporation, “doing business” in any of these major economies will likely trigger reporting requirements, making it increasingly difficult to avoid disclosure.
Don’t Navigate this Alone
ClimeCo serves as a knowledgeable advisor, helping organizations move beyond the confusion of emerging state mandates to find clear, customized sustainability pathways. Schedule a complimentary conversation to see if your organization is applicable at info@climeco.com.
Works Cited
New York State Senate Bill S9072A: Establishes the Climate Corporate Data Accountability Act
New York State Assembly Bill A4282A: Assembly companion bill to S9072A
New York State Senate Passes Legislation to Strengthen Climate and Environmental Protections
Illinois House Bill 3673: Climate Corporate Data Accountability Act
Greenly: New York Passes the Climate Corporate Data Accountability Act: 3 Pillars of S9072
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