Article

May 12, 2026

Regulatory round-up: New York’s new and pending climate laws and strategic business impacts

As federal greenhouse gas regulatory frameworks face uncertainty following a rescission of key Clean Air Act greenhouse gas findings, New York state is developing its own corporate climate disclosure and emissions reporting program. Our experts detail the new laws and why they will be critical to sustainability efforts in the years to come.

Government & Public

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Regulations

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On February 12, 2026, USEPA rescinded the 2009 Greenhouse Gas (GHG) Endangerment Finding under the Clean Air Act, which served as the legal determination that GHGs endanger public health and welfare. This finding had served nearly two decades of federal climate regulation, including vehicle emissions standards and broader carbon regulatory programs.

This reversal signals more than a policy adjustment. It represents a structural shift in climate governance authority from the federal level toward states and private-sector accountability mechanisms.

In response, states are advancing their own frameworks rather than slowing climate regulation. California is advancing rulemaking and implementation under SB 253 (Climate Corporate Data Accountability Act) and SB 261 (Climate-Related Financial Risk Act), including detailed guidance on emissions reporting boundaries, third-party assurance requirements, and risk disclosure expectations.

New York is developing parallel mandatory GHG reporting and disclosure regulations through its Department of Environmental Conservation (DEC), expanding reporting obligations for both emitting sources and fuel suppliers.
New York is also developing parallel mandatory corporate climate disclosure and emissions reporting programs that will reshape how organizations measure and verify GHG emissions.

Thus, the regulatory landscape is fragmented across jurisdictions but converging in expectation. There is growing recognition that GHG data is no longer solely an environmental metric but has become a core element of corporate transparency and strategic decision-making.

New York’s latest climate laws: What they are and why they matter

6 NYCRR Part 253: Mandatory Greenhouse Gas Reporting Program

New York’s Part 253 GHG reporting framework operates under environmental regulatory authority. It focuses primarily on emissions reporting for certain entities under state jurisdiction, particularly sources already regulated for emissions under environmental permitting regimes.

Key characteristics:

  • Applies to specific regulated sources or sectors
  • Anchored in environmental regulatory compliance
  • Does not impose broad corporate Scope 3 disclosure
  • Functions primarily as greenhouse gas emissions reporting, not enterprise-level transparency

In other words, Part 253 is closer in design to California’s Mandatory Reporting Rule (MRR), source-based and regulatory, rather than enterprise-wide disclosure legislation.

Who should report

(Reference: Mandatory Greenhouse Gas Reporting - NYSDEC)

Reference: Mandatory Greenhouse Gas Reporting - NYSDEC

Key compliance dates

(Reference: Mandatory Greenhouse Gas Reporting - NYSDEC)

Reference: Mandatory Greenhouse Gas Reporting - NYSDEC

Annual third-party verification required  for emission sources that meet listed thresholds

Reference: Mandatory Greenhouse Gas Reporting - NYSDEC

Reference: Mandatory Greenhouse Gas Reporting - NYSDEC

SB 9072A: Corporate Climate Disclosure Legislation

On February 10, 2026, the New York State Senate passed the Senate Bill 9072A or the Climate Corporate Data Accountability Act. SB 9072A mirrors California’s SB 253 model.

If enacted, SB 9072A would:

  • Apply to companies with over $1 billion in revenue and do business in New York
  • Require annual public disclosure of Scope 1, 2, and 3 emissions
  • Establish third-party assurance requirements
  • Create a state-managed disclosure platform

Critically, SB 9072A is legislative and enterprise-based, not source-based. It is not limited to traditional regulated emitters. It extends accountability to corporations whose emissions footprint may be embedded primarily in their value chains.

As of May 2026, SB 9072A has passed the State Senate and remains under Assembly consideration. If approved by the Assembly, the bill will go to Governor Hochul for signature. It is not yet law, but current legislative momentum suggests it remains a viable regulatory development.

Why the distinction matters

NY Part 253 and NY SB 9072A serve complementary but different objectives:

  • NY Part 253 = Environmental compliance reporting
  • NY SB 9072A = Corporate carbon transparency mandate

One regulates emissions sources and the other focuses on corporate climate accountability.

For companies already reporting under environmental permits, NY Part 253 may represent incremental compliance adjustments. However, SB 9072A would require consolidated enterprise inventories, Scope 3 quantification, public disclosure, and third-party verification.

This shift requires entirely different internal infrastructure, including procurement engagement, data governance, supply chain emissions modeling, internal controls, and external verification.

NY and CA climate reporting and disclosure frameworks

NY and CA climate reporting and disclosure frameworks

Convergence and strategic implications

New York’s approach aligns with California’s climate disclosure framework, though timelines and implementation details differ. California’s requirements are already enacted and moving through rulemaking, while New York’s SB 9072A legislation remains pending. Companies operating in both jurisdictions will likely benchmark to the more stringent standards to ensure compliance and operational consistency.

The strategic implications extend beyond regulatory compliance. Mandatory disclosure regimes elevate climate data into core corporate decision-making processes, influencing capital allocation, investment strategy, risk management, and value-chain engagement.

Organizations that treat emissions data as a strategic asset rather than a compliance obligation can derive insights that improve operational efficiency, strengthen governance, and enhance long-term resilience.
Ultimately, the evolving landscape reflects a broader expectation that corporations measure and manage environmental impacts with the same rigor applied to financial performance. As climate considerations increasingly influence market behavior and stakeholder expectations, the ability to generate reliable GHG emissions data and integrate it into strategic planning will become a competitive differentiator.

Want to know more?

  • Alice Roberts

    Senior Managing Consultant, GHG Emissions Lead

    Alice Roberts