New York's Climate Reporting Landscape: What Companies Need to Know
Background
Signed into law in 2019, New York's Climate Leadership and Community Protection Act (CLCPA) set ambitious goals for curtailing the state's greenhouse gas emissions: 40% below 1990 levels by 2030, and 85% below 1990 levels by 2050, New York State Senate with 100% zero-emission electricity by 2040. While implementation has been mired in political conflict, with Governor Hochul proposing to delay key deadlines and a broad environmental coalition declaring the proposal "not acceptable" Nylcv, two distinct reporting frameworks are advancing independently and deserve close attention from companies operating in New York.¹
Track 1: Part 253 — Facility-Based GHG Reporting
In December 2025, the DEC adopted the Mandatory GHG Reporting Program under 6 NYCRR Part 253, requiring specified GHG emitters to annually report emissions beginning in 2026. It is solely a data collection requirement and imposes no emission reduction obligations. Holland & Knight It became effective December 25, 2025, as a regulatory action, it did not require legislative approval or the Governor's signature.
Part 253 applies to physical operations in New York emitting 10,000 metric tons of CO2e or more annually, as well as certain fuel suppliers and electric power entities supplying into the state. Importantly, Part 253 does not use the Scope 1, 2, 3 framework common in corporate ESG reporting. Instead, it requires reporting by emissions source category, such as stationary combustion, fugitive emissions, and fuel supply volumes, focused on quantifying total GHG emissions from specific facility operations and supply chains.
Key deadlines:
Data collection: began January 1, 2026
GHG Monitoring Plans (large emitters²): due December 31, 2026
First emissions reports (covering 2026 data): due June 1, 2027
Violations may result in significant civil penalties, including per-day penalties for continued noncompliance. Mondaq
Track 2: CCDAA — Corporate-Level Disclosure
The Climate Corporate Data Accountability Act (CCDAA) is separate, standalone legislation, independent of the CLCPA. Per the New York State Senate, S9072A passed the Senate on February 10, 2026, and would require businesses with over $1 billion in annual revenue doing business in New York to publicly disclose Scope 1, 2, and 3 emissions, the full value chain, with third-party assurance requirements. It is pending in the Assembly and has not yet reached the Governor's desk.
Unlike Part 253, the CCDAA applies at the corporate level regardless of physical presence in the state, and uses the Scope 1, 2, 3 framework familiar to ESG practitioners. This makes it particularly relevant for financial services firms, private equity managers, and professional services companies with significant New York revenue exposure but no emissions-generating facilities. If enacted, reporting would begin in 2028.
The Bottom Line
These two tracks are complementary but legally distinct, and political uncertainty around the CLCPA does not appear to directly affect either. Companies should assess their exposure to both now, waiting for regulatory certainty is not a strategy.
Reflects developments as of early April 2026. Readers are encouraged to seek legal counsel for guidance specific to their circumstances.
¹ "Companies operating in New York" means different things under each track. Under Part 253, a company is in scope if it owns or operates a physical facility meeting the emissions threshold, or supplies fuel or electricity into the state. Under the CCDAA, any company with over $1 billion in revenue conducting business in New York may be covered — even without physical facilities in the state.
² Under Part 253, a "Large Emission Source" is a facility or supplier meeting or exceeding 25,000 metric tons of CO2e annually, subject to mandatory GHG Monitoring Plan submission and annual third-party verification.
Sources
New York State, Climate Leadership & Community Protection Act
New York State Senate, CLCPA Original Legislation, S6599 (2019)
New York State DEC, Mandatory GHG Reporting Program, 6 NYCRR Part 253
New York State Senate, Climate Corporate Data Accountability Act, S9072A
Environmental Defense Fund, Governor Hochul Seeks to Weaken New York's Leading Climate Law
New York Civil Liberties Union, New York Passed a Historic Climate Justice Bill. Now Hochul Wants to Water It Down.
New York League of Conservation Voters, Statement on Proposed CLCPA Changes
The Nature Conservancy et al., Joint Statement on Proposed CLCPA Changes