New York GHG Disclosure

The Bill

What Is the Climate Corporate Data Accountability Act?

A New York State bill (S9072A) that, if signed into law, would require U.S.-based companies with over $1 billion in annual revenue to publicly report their Scope 1, 2, and 3 greenhouse gas emissions each year. It closely mirrors California's SB 253.

The bill reflects a broader shift: state-level climate disclosure is accelerating, even in the absence of federal requirements. For companies already tracking SB 253, this isn't a new direction — it's an expansion.

If Enacted, the Act Would:

Require annual reporting of Scope 1, 2, and 3 emissions

Be overseen by the NY Department of Environmental Conservation

Apply to U.S.-based companies exceeding $1 billion in revenue

Align closely with California's SB 253 framework

01

Scope 1

Direct emissions from sources your company owns or controls — fleets, combustion, on-site fuel use.

02

Scope 2

Indirect emissions from purchased energy — electricity, steam, heating, and cooling across operations.

03

Scope 3

Value-chain emissions across upstream and downstream activities — suppliers, logistics, product use.

NY vs California

How Does New York's Law Compare to California's SB 253?

New York's Climate Corporate Data Accountability Act is closely modeled after California's SB 253. Both apply to U.S.-based companies with revenues over $1 billion and require Scope 1, 2, and 3 annual reporting. The primary difference is timeline.

FACTOR

CALIFORNIA SB 253

NY CCDAA (S9072A)

Revenue Threshold

$1B+

Emissions Scope

Scope 1, 2, 3

Scope 1 & 2 Start

2026

2028

Scope 3 Start

2027

2029

Status

Active Law

Pending Assembly & Signatur

Status

CARB

NY DEC

HOW WE HELP

How Clearyst Helps Companies Prepare for NY GHG Disclosure

GHG disclosure is not a one-time project. It's a system. We help you build that system — from initial scope determination through audit-ready reporting — so your organization isn't rebuilding the process each year.

01 Scope and Applicability Assessment

Determines whether and when your company must comply with the CCDAA based on the $1 billion revenue threshold, organizational structure, and reporting entity definition.

Confirm applicability based on revenue and structure
Define reporting boundaries across entities
Align NY requirements with SB 253 programs
Clarify timelines and obligations

Outcome: Clear direction so you invest in the right level of preparation.

02 GHG Inventory Development: Scope 1, 2, and 3

A systematic accounting of total greenhouse gas emissions across Scope 1, 2, and 3. The foundational requirement for compliance — and the most resource-intensive to build correctly.

Complete, audit-ready inventories aligned to GHG Protocol
Scope 1, 2, and 3 emissions coverage
Standardized methodologies across business units
Repeatable, scalable data structures

Outcome: One inventory that supports NY, SB 253, and broader ESG reporting.

03 Data Collection and Management

Coordination across internal teams and external partners, especially for Scope 3 categories. Building scalable systems early reduces long-term reporting burden.

Cross-functional data collection processes
Supplier engagement for Scope 3 data
Standardized methodologies and emission factors
Year-over-year reporting systems

Outcome: Reliable data that reduces risk and improves efficiency each cycle.

04 Reporting and Disclosure Preparation

Transforms your inventory into a structured, compliant report aligned with regulatory expectations and stakeholder scrutiny.

Prepare disclosure-ready emissions reports
Validate completeness and consistency
Align with GHG Protocol and regulatory expectations
Coordinate across multiple reporting frameworks

Outcome: A report that meets requirements and supports stakeholder transparency.

05 Assurance Preparation

Third-party verification of your emissions data. Even before requirements are finalized, preparing for assurance is critical.

Complete documentation and audit trails
Clear methodologies and assumptions
Internal controls and review processes
Readiness for future verification requirements

Outcome: Reduced audit risk and stronger credibility from day one.

Why Start Now

Why Start Building Your GHG Inventory Before the Law Takes Effect?

Waiting creates risk. Starting early creates control. The 2027 data year arrives faster than it looks — companies that move early won't just meet compliance requirements, they'll build a durable capability.

Scope 3 Takes Time

Data collection across suppliers and value chains cannot be built quickly or retroactively.

2027 Data Year Is Close

By the time the law is final, most teams will be behind on collection infrastructure.

SB 253 Overlaps

Aligning California and New York programs now eliminates duplicate work later.

Investors Already Ask

Customers and capital markets are requesting emissions data independent of regulation.

The companies that move early won't just meet compliance requirements — they'll build a durable capability.

Frequently Asked Questions About CSRD

1. What is the Climate Corporate Data Accountability Act?

A New York bill requiring companies with over $1 billion in revenue to report Scope 1, 2, and 3 emissions annually. It has passed the senate and is in the assembly, after which it will require the Governor’s signature.

2. Which companies are in scope?

U.S.-based companies exceeding $1 billion in annual revenue, regardless of headquarters location.

3. When does reporting start?

Scope 1 and 2 reporting begins in 2028 (for 2027 data), with Scope 3 following in 2029.

4. What are Scope 1, 2, and 3 emissions?

Scope 1: direct emissions
Scope 2: purchased energy
Scope 3: value chain emissions

5. How is this different from SB 253?

The requirements are similar, but SB 253 is already active. New York’s law follows a similar structure with a later start date.

6. What does compliance involve?

Building a full GHG inventory, collecting and validating data, and preparing disclosures for verification.

Preparing for the Climate Corporate Data Accountability Act