New York Senate Bill S3456: The Climate Corporate Data Accountability Act

New York Senate Bill S3456, also known as the Climate Corporate Data Accountability Act (CCDAA), has been introduced by Senator Brad Hoylman-Sigal to increase corporate transparency and accountability regarding greenhouse gas (GHG) emissions. This bill, currently under consideration in the Senate Finance Committee, aims to require large companies operating in New York to publicly report their emissions data across three scopes.

Purpose of the Bill

The Climate Corporate Data Accountability Act targets U.S.-formed entities, both public and private, with annual revenues over $1 billion that operate in New York. It mandates the disclosure of corporate GHG emissions across three categories:

• Scope 1: Direct emissions from owned or controlled sources
• Scope 2: Indirect emissions from purchased electricity, steam, heating, or cooling
• Scope 3: Indirect emissions from the value chain, including suppliers and product use

Key Requirements

1. Emissions Reporting Timeline

o 2027: Reporting of Scope 1 and 2 emissions for the 2026 fiscal year
o 2028: Expansion to include Scope 3 emissions

2. Verification

o Limited assurance for Scope 1 and 2 emissions starting in 2027
o Reasonable assurance for Scope 1 and 2 emissions from 2031, with potential limited assurance for Scope 3 by 2031, based on regulatory review.

3. Public Disclosure Platform

A digital platform will be established to make emissions data publicly accessible, ensuring transparency.

4. Enforcement and Penalties

o The New York Attorney General will oversee enforcement.
o Penalties for non-compliance could be as high as $100,000 per day, with a cap of $500,000 per reporting year.
o A safe harbor provision will protect entities that report Scope 3 emissions in good faith.

Funding Mechanism

To ensure the smooth administration and enforcement of the Act, a Climate Accountability and Emissions Disclosure Fund will be created. The fund will be financed by annual fees paid by reporting entities.

Regulatory Oversight

The New York State Department of Environmental Conservation (DEC) will be tasked with adopting detailed regulations by the end of 2026, setting the framework for how companies will report and verify their emissions data.

Affected Sectors

The bill’s broad scope means that various sectors will be impacted, including:

• Finance and insurance
• Technology
• Retail and consumer goods
• Manufacturing and industrial
• Energy and utilities
• Healthcare and pharmaceuticals
• Transportation and logistics

Why This Matters?

With growing pressure from both regulatory bodies and the public to tackle climate change, New York is positioning itself as a leader in corporate climate accountability. This bill, if passed, would set a national precedent for corporate transparency on emissions and align New York with global sustainability goals.

The CCDAA represents a significant step toward holding major corporations accountable for their environmental impact. Companies with large operations in New York are advised to prepare for the stringent reporting and verification requirements that could reshape corporate climate strategy.

Reference: New York Senate Bill