This week’s reading time: 6 minutes

Welcome to another edition of The Green Executive Briefing. In under 10 minutes, you’ll be fully updated on the latest happenings in Sustainability and ESG every Tuesday at 8am EST. 🌎

We sift through a vast array of articles and data from trusted sources, distill the information, and present it to you in simple, bite-sized pieces every week. 🌍

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In this edition, we'll cover:

• State-by-State Climate Disclosure Bills: Explore how New York, New Jersey, Colorado, and Illinois are leading the charge on corporate emissions transparency requirements. 📊

• Critical Implementation Timelines: Mark your calendar for key compliance dates with reporting obligations beginning as early as 2025 in Illinois and extending through 2029 for various scopes. ⏱️

• Navigating Multi-State Compliance: Strategies for companies operating across state lines to develop standardized reporting systems that satisfy different regulatory frameworks. 🧭

• Penalties and Enforcement Mechanisms: Understand the financial risks of non-compliance, with penalties reaching $100,000 per day in some jurisdictions. ⚖️

• Proactive Preparation Strategies: List essential steps your organization should take now to prepare for the new reporting landscape, regardless of where you operate. 📝

🌟 Spotlight: Dylan Brown

Dylan Brown is an expert in GHG Accounting, Sustainability Strategy, and Environmental Permitting. The coolest thing about him? He’s a big Philadelphia Eagles fan.

“I’m an Environmental, Health & Safety (EHS) professional with a strong focus on ESG and sustainability. I ensure risk mitigation strategies align with operational safety and regulatory compliance.”

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Want to get featured in the spotlight? Reply to this email: [email protected]

Intro

In a significant shift toward corporate environmental accountability, several U.S. states are advancing legislation requiring large businesses to disclose their greenhouse gas emissions. New York, New Jersey, Colorado, and Illinois have introduced bills that would mandate comprehensive climate data reporting for companies with annual revenues exceeding $1 billion.

These initiatives signal a growing trend of state-level climate action that will reshape corporate reporting obligations nationwide.

Main

New York's Climate Corporate Data Accountability Act

New York lawmakers have introduced companion bills (A04282 and S03456) that would require businesses with revenues over $1 billion operating in the state to disclose their carbon footprint. Key provisions include:

• Implementation Timeline: Reporting entities would first disclose scope 1 and 2 emissions data in 2027, followed by scope 3 emissions in 2028

• Enforcement Mechanism: The New York Attorney General can bring civil actions against non-compliant entities

• Potential Penalties: Up to $100,000 per day for willful violations, with a cap of $500,000 per reporting year

• Similarity Note: The legislation mirrors California's Climate Corporate Data Accountability Act

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New Jersey Follows Suit

New Jersey's S4117, also titled the "Climate Corporate Data Accountability Act," follows a similar framework:

• Scope: Applies to entities with annual revenue exceeding $1 billion doing business in New Jersey

• Disclosure Requirements: Companies must report scope 1, 2, and 3 greenhouse gas emissions

• Verification: Third-party assurance or verification will be required

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Colorado's Emissions Transparency Push

Colorado has introduced HB25-1119, which would:

• Begin Reporting: Scope 1 and 2 emissions disclosure starting January 1, 2028

• Expand Requirements: Scope 3 emissions reporting beginning January 1, 2029, with additional specified sources by 2031

• Set Standards: Requires calculation using the Greenhouse Gas Protocol Corporate Accounting and Reporting Standard

• Establish Penalties: Civil penalties up to $100,000 for each day of non-compliance

• Empower Regulators: The Colorado Air Quality Control Commission would have authority to implement and adjust reporting deadlines

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Illinois Considers Accelerated Timeline

Illinois's Climate Corporate Accountability Act (HB4268) proposes the most aggressive implementation schedule:

• Rapid Deployment: If passed, reporting would begin January 1, 2025, for the 2024 calendar year

• Digital Platform: Requires the Secretary of State to develop a publicly accessible emissions registry by January 2025

• Verification Requirements: Disclosures would need independent verification by an approved third-party auditor

• Current Status: The bill has been referred to the Illinois House Rules Committee with consideration expected after the legislative recess ends in November 2024

Main

What This Means for Businesses

These state initiatives represent a significant shift in climate disclosure requirements across the United States. Companies operating in multiple states will soon face a complex patchwork of reporting obligations with potentially substantial penalties for non-compliance.

Organizations with revenues exceeding the $1 billion threshold should:

• Begin developing robust emissions tracking systems

• Prepare for third-party verification processes

• Monitor legislative developments across states where they conduct business

• Consider adopting standardized reporting frameworks aligned with the Greenhouse Gas Protocol

WRAPPING UP

OUR TAKE: As more states advance climate disclosure legislation, companies that proactively develop comprehensive emissions reporting capabilities will be better positioned to navigate this evolving regulatory landscape. The trend toward mandatory climate disclosures shows no signs of slowing, making early preparation a strategic imperative for forward-thinking organizations.

P.S. When you’re ready, here’s how I can help you:

1. Download our Dashboard GHG Accounting Scope 1, 2 & 3. Customize it with your organization's numbers to build a compelling business case.

2. Refer 1 other sustainability leader (see Click to Share button below)

3. Book a Consultation: Click HERE

   1. GHG Accounting Strategies (Scope 1, 2 & 3) 

   2. ISO 14001 Compliance (Environmental Management)