New York’s Climate Corporate Accountability Act (CCDAA)

What Companies Need to Know

On February 10, 2026, the New York State Senate passed the Climate Corporate Accountability Act (CCDAA), marking a significant step in the push for state-mandated emissions reporting. If enacted, the Act will require large companies doing business in New York to publicly disclose their Scopes 1, 2, and 3 greenhouse gas (GHG) emissions. Because the bill has not been signed into law, all provisions discussed here reflect proposed requirements. Companies should monitor developments closely as the final version may look different.

Like other states introducing legislation on corporate climate disclosure, New York’s CCDAA is largely inspired by California’s SB 253.  The emergence of corporate climate requirements in New York reflects a broader national trend of states pursuing climate transparency for companies independently of federal action.

Related

Preparing for California’s Climate Disclosure Laws

Current Status

The CCDAA was established by Senate Bill 9072A. Its companion Assembly Bill 4282, is currently under review. If the bill passes the Assembly, it will move to Governor Kathy Hochul’s desk, and if signed, the act will take effect 180 days later.

Who Would Be Covered

Just like in California, New York’s CCDAA applies to U.S.-based companies that do business in the state and have total annual revenues over $1 billion.

Key Requirements & Provisions

For companies that meet the threshold, the law would require:

GHG emissions reporting: Scopes 1-3: Public annual disclosure of GHG emissions across all three scopes, in line with the GHG Protocol:

• Scope 1: Direct emissions from owned or controlled sources
• Scope 2: Indirect emissions from the generation of purchased energy
• Scope 3: All other indirect emissions across a company’s value chain

Third-party assurance: All reporting entities must obtain independent third-party assurance, as follows:

• For Scope 1 and Scope 2, the requirements begin at a “limited assurance” standard and increase up to “reasonable assurance,” a more rigorous standard, starting in 2032
• For Scope 3, the New York Department of Environmental Conservation (DEC) will review trends in assurance practices; based on its findings, limited assurance requirements may take effect beginning in 2032.

Enforcement

Complete non-compliance carries financial risk. Companies that willfully fail to comply may face penalties of up to $100,000 per day.

When it comes to Scope 3 reporting starting in 2029, companies that make a genuine effort to report, even imperfectly, will not be penalized for data accuracy issues for the first few years.

Between 2029 and 2032, penalties for Scope 3 reporting are limited strictly to cases of non-filing. Entities will not face civil action for misstatements in their Scope 3 disclosures, provided those statements were made with a reasonable basis and in good faith.

Timeline

• By December 31, 2027: The DEC would need to finalize implementing regulations for the law
• 2028: First Scope 1 and Scope 2 disclosures would be due, based on 2027 emissions data (limited assurance required)
• 2029: Scope 3 disclosures would begin, with an emphasis on good faith effort
• 2032: Reasonable assurance required for Scope 1 and Scope 2 disclosures; Scope 3 assurance requirements are not yet determined

How to prepare: Companies who want to stay ahead of this emerging regulation should treat 2027 as a planning year. With DEC regulations still to be finalized, organizations that begin building their emissions inventory and assurance programs now will be better positioned to comply when requirements take effect.

How G&A Can Help

Navigating evolving climate disclosure requirements demands both regulatory expertise and practical implementation support.

G&A’s climate team can help your organization with emissions inventory development, assurance readiness, Scope 3 value-chain data collection, regulatory monitoring, and cross-jurisdictional strategy for companies preparing for compliance with New York’s CCDAA and other states’ disclosure requirements.

Whether you’re just beginning to assess your CCDAA exposure or already building out your disclosure infrastructure, set up a call with our team to learn how G&A can support your climate reporting goals.

Neva Modric

Sustainability Analyst, G&A Institute

Neva Modric is a Sustainability Analyst at G&A Institute. Her role includes conducting research to support client engagements, assisting with double materiality assessments, developing sustainability reports, analyzing ESG data, and providing general sustainability consulting. She is passionate about helping companies drive positive, sustainable impact that benefits both people and the environment.