State Climate Reporting Laws: A Guide to US Climate Disclosure Laws

Federal climate disclosure rules may be stalled, but state climate reporting laws are not – and for large companies operating across the US, the compliance clock is already running.

The situation is more manageable than it looks. Most state rules are built from the same blueprint: California moved first, and every state that followed used its framework as the template. That means a reporting system aligned to California’s requirements will cover most of what other states require. You may need to adjust as new legislation advances, but you will not be starting from scratch each time.

This guide explains where each state stands, what the rules require, and the four steps your company should be taking now.

What US Climate Disclosure Laws Have in Common

Every active state disclosure rule targets companies doing business in that state above a certain revenue threshold, typically $1 billion. Each requires reporting Scope 1 and 2 emissions, phased third-party assurance, and eventual escalation to reasonable assurance.

The differences are narrower than they appear. They come down to three variables:

Whether Scope 3 is required. California and New York both include it. New Jersey removed it during committee. Illinois and Colorado would have included it had they advanced.

Whether climate risk reporting is required. California is currently the only state with an active climate risk rule (SB 261) for companies with revenue over $500 million. New York’s companion bill has not advanced.

The assurance timeline. States are phasing in limited assurance first, then increase the requirement for reasonable assurance in later years.

If you build to California’s standard, you have built for all of them. The other rules, so far, are subsets.

State Climate Reporting Laws: Where Each State Stands

California: Rules Adopted and Active

California was first, and its framework is the most comprehensive active US climate disclosure law. If you operate here, preparation should already be underway.

SB 253 (Emissions Reporting) requires companies with more than $1 billion in revenue doing business in the state to report emissions. Rules were finalized in February 2026. The first Scope 1 and 2 reporting deadline is August 10, 2026. Scope 3 becomes mandatory in 2027.

Limited assurance is not required in year one, but the California Air Resources Board (CARB) strongly advises it, and it becomes mandatory in 2027. Treating year one as a dry run on assurance is the right move.

SB 261 (Climate Risk Reporting) requires companies with more than $500 million in revenue to disclose climate-related financial risks every two years, aligned with TCFD or ISSB S2 standards. The rule is currently under a court-ordered stay, but more than 100 companies have already submitted voluntary TCFD-aligned reports to the CARB public docket. A ruling is expected in the coming months.

California’s “doing business” definition covers companies that are headquartered or incorporated in the state, generate California sales above $735,019 (2024 threshold) or 25% of total revenue, or otherwise meet the state’s standard.

Looking for the latest on California’s rules?
👉 We regularly share updates in our “California Climate Law Updates” article here.

New York: Advancing in 2026

New York’s emissions disclosure bill (S9072) was reintroduced in 2026 after narrowly failing in 2025. It has passed the State Senate and currently sits with the State Assembly.

The bill mirrors California’s SB 253 closely. The main differences are a slightly later start date and modified Scope 3 safe harbor provisions. Companies with more than $1 billion in revenue doing business in the state would be covered.

New York’s climate risk bill (S03697) was referred to environmental conservation in January 2026 but has not advanced.

For companies already preparing for California, New York requires almost no additional work. The frameworks are nearly identical. The only gap worth watching is Scope 3 safe harbor language, which may offer more flexibility in New York than in California — a meaningful detail if your value chain data is still maturing.

New Jersey: A Simpler Version of the Same Framework

New Jersey’s rule (S679 1R) was reintroduced in 2026 after failing in 2025. Originally modeled on California and New York, it was amended during committee to remove Scope 3 reporting entirely. It covers companies with more than $1 billion in revenue doing business in the state.

If the bill passes in 2026, public reporting would begin in 2030.

New Jersey is the most lenient of the three active frameworks: no Scope 3, a private first year, and the longest runway to reasonable assurance. If you are already preparing for California, New Jersey adds nothing to your workload.

Illinois, Washington, and Colorado: Stalled, Not Dead

Three other states advanced bills modeled on California’s framework. None are currently active, but all three reflect genuine legislative intent.

Illinois HB 3673 would have required companies above $1 billion in revenue to report and obtain third-party assurance for Scope 1, 2, and 3 emissions, with 180 days between Scope 1/2 and Scope 3 submission. It was referred to the Rules Committee in March 2025 and has not been reintroduced.

Washington SB 6092 started as a California-aligned emissions reporting bill, then was downgraded to a directive for the Department of Ecology to study the (now defunct) SEC rule and issue recommendations. It died in early 2025 and has not been reintroduced.

Colorado HB 25-1119 would have required companies above $1 billion to report Scope 1, 2, and 3 emissions beginning in 2028, with a unique three-year phase-in across different Scope 3 categories. It lost an 8-5 vote in the Committee on Appropriations and has not been reintroduced.

None of these are live obligations today. But companies preparing for California are already prepared for what any of these would require. If any of them advance, you will not be starting from zero.

How to Navigate State Climate Reporting Laws Across Multiple States

For companies operating across multiple states, the practical question is not “which states do I need to comply with?” It is: “what reporting architecture do I need to build once?”

The answer is straightforward so far. Build to California’s standard, and you have built for all of them.

A company preparing for California’s SB 253 will measure Scope 1 and 2 emissions, prepare Scope 3 value chain reporting, establish data quality controls that meet assurance standards, and align climate risk disclosures with TCFD or ISSB S2. That is the full stack. New York requires the same. New Jersey requires a subset. The stalled states would have required the same or less.

Building that infrastructure once, rather than reacting as each new state deadline approaches, is the lower-cost path. Companies that standardize early spend less than those who build reactively, and they spend it under less pressure.

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Four Steps to Take Now

If your company generates more than $500 million in annual revenue and operates in any major US market, state climate reporting laws either already apply or likely will soon. Here is where to focus.

1. Map your regulatory exposure. Start with revenue and geography. Do you do business in California, New York, or New Jersey above the applicable thresholds? California’s “doing business” definition is specific: headquartered or incorporated there, California sales above $735,019 or 25% of total revenue. Expect other states to define it similarly. Know where you are in scope before you build anything.

2. Get Scope 1 and 2 measurement right. Every active rule requires Scope 1 and 2 in the first year of reporting. This is the foundation everything else sits on. CARB has published an SB 253-aligned reporting template that is a practical starting point even for companies subject to other state rules. Invest in a methodology that will hold up to assurance scrutiny, not just a number that gets you to the deadline.

3. Get ahead of assurance. Limited assurance is technically optional in California’s first reporting year, but mandatory in year two, and required from day one in New York and New Jersey. Companies that begin assurance readiness work early find and fix data quality issues before they become compliance problems. The standard for emissions data is moving toward the standard for financial data. Getting there early is easier than getting there under pressure.

4. Start Scope 3 planning now. California and New York both require Scope 3 reporting, with a one-year runway after Scope 1 and 2 begins. That sounds like sufficient time. It rarely is. Scope 3 requires supplier engagement, value chain mapping, and data collection that consistently takes longer than companies expect. Start supplier conversations before the deadline is close.

The Bottom Line

State climate reporting laws are already here. California’s first reporting deadline is August 10, 2026. New York is advancing. New Jersey is advancing. The patchwork is real, but it is a manageable one, built largely from the same parts.

Companies that prepare now reduce costs, reduce risk, and avoid the last-minute scramble. Companies that wait pay more for the same outcome, under more pressure.

Good.Lab works with companies to assess regulatory exposure, build standardized reporting systems, and prepare for assurance before it becomes mandatory. If you are not sure whether your company is in scope, or where to start, contact our team here.