These states are picking up the corporate climate disclosures slack
As other entities relinquish the responsibility of holding corporations to account on climate issues, states are stepping into the breach. The post These states are picking up the corporate climate disclosures slack appeared first on Trellis.
The European Union is scaling back its landmark CSRD corporate climate disclosure law, while the SEC recently stopped defending in court its corporate emissions disclosure law. But as a result of existing and on-the-way state-level laws, companies will have to keep moving forward with plans to monitor and report Scope 1, 2 and 3 emissions.
Here is a list of states that already have laws mandating corporate emissions disclosure or have introduced such bills. Trellis will continue to update it in real time as new laws come on line.
States with laws
California
SB 253 Climate Corporate Data Accountability Act
Who it impacts: Any company, public or private, that does business in the state with revenues exceeding $1 billion.
What will be reported and when: Scope 1 and 2 emissions based on 2025 data, due in 2026; Scope 3 disclosures, from downstream and upstream value chains, due in 2027.
SB 261 Climate-Related Financial Risk Act
Who it impacts: Companies with $500 million or more in annual revenue.
What will be reported and when: Financial risks directly caused by climate change, along with mitigation plans that address those risks, due January 2026, then biennially thereafter.
States considering laws
Colorado
Greenhouse Gas Emissions Act HB 25-1119
Status: Introduced on January 28, 2025.
Who will it impact: Companies — including subsidiaries — operating in the state with revenues exceeding $1 billion.
What will be reported and when: Scope 1 and 2 emissions, beginning in 2028, then annually thereafter; Scope 3 emissions, with partial disclosure for purchased, capital goods and product expected in 2029, with categories added in 2030 and 2031. Includes an option for refraining from disclosing certain items based on freedom of speech considerations.
Illinois
Climate Corporate Accountability Act HB 3673
Status: Introduced on February 18, 2025.
Who will it impact: U.S. businesses operating in the state with revenues exceeding $1 billion.
What will be reported and when: Scope 1, 2 and 3 emissions, due January 1, 2027, then annually thereafter. Emissions will be calculated using the GHG Protocol Corporate Accounting and Reporting Standard. State verified third party auditors would be required to independently verify the reports.
New Jersey
Climate Corporate Data Accountability Act SB 4117
Status: Introduced on February 3, 2025.
Who will it impact: U.S. entities doing business in the state with revenues exceeding $1 billion.
What will be reported and when: Three years after the law is enacted companies will submit a report on GHG emissions to the Department of Environmental Protection (DEP) and a non-profit chosen by DEP, with annual reports thereafter. Scope 1 and 2 emissions must be publicly accessible four years after enactment; five years for Scope 3. Additionally, a qualified third party auditor must verify an assurance engagement report at a limited assurance level, with a planned move to reasonable assurance eight years after enactment.
New York
Climate Corporate Accountability Act SB 3456
Status: Introduced on January 27, 2025, following a failed first attempt in 2023.
Who will it impact: Companies operating in the state with revenues exceeding $1 billion.
What will be reported and when: Scope 1 and 2 emissions, beginning in 2027, then annually thereafter; Scope 3 emissions, beginning in 2028, then annually thereafter. Companies must submit reports in accordance with the GFG Protocol Corporate Account and Reporting Standard and GHG Protocol Value Chain Accounting and Reporting Standard. The final report must be verified by a third party auditor at limited assurance, with a planned move to reasonable assurance in 2031.
Washington
Washington Fashion Sustainability Accountability Act HB 1107
Status: Introduced on December 20, 2024, after a similar bill failed to make it out of committee earlier in the year.
Who will it impact: All fashion producers — that is, anyone selling, offering or distributing apparel or footware — in the state.
What will be reported and when:
All companies will report:
- Products containing high priority chemicals
- Definition of marketing terms, including “sustainable,” “green,” “low impact” and “environmentally friendly”
- Disposal methods and volume of unwanted excess products not sold in store
- Current initiatives and targets set to reduce environmental impacts
Companies with a gross income of $100 million or more will also report:
- Established environmental due diligence policies and outcomes
- Working conditions of company and its direct suppliers.
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