Carbon reporting for New York companies

Last reviewed: 11 November 2026.

Three rules, three different scopes

NYC Local Law 97: Who it covers: Covered buildings in New York City; Status: In force. First compliance period 2024–2029; stricter limits from 2030; What it asks for: An annual building emissions report, due 1 May each year (NYC DOB)
NY S9072A, Climate Corporate Data Accountability Act: Who it covers: Companies with over $1 billion in revenue doing business in New York; Status: Proposed. Passed the Senate on 10 Feb 2026 (40–22); now in the Assembly (A4282); What it asks for: As written: Scope 1 and 2 from 2028, Scope 3 from 2029; the DEC writes the rules; the Attorney General enforces (NY Senate)
California SB 253: Who it covers: US companies with over $1 billion in revenue doing business in California, including New York-headquartered ones; Status: In force for Scope 1 and 2. First reports were due 10 Nov 2026; Scope 3 is now before the courts; What it asks for: Scope 1 and 2 for the prior fiscal year (CARB, Ninth Circuit)

If you own or lease buildings in New York City

Local Law 97 measures emissions per building, not per company. Limits tighten from 2030 (DOB), so energy and electrification plans made now decide 2030 compliance. A building's compliance path can change when DOB updates its covered buildings list (DOB notice). For filing rules and extensions, see DOB's LL97 FAQ.

If you're a large company headquartered in New York

California comes first. "Doing business in California" brings many New York companies into SB 253 today, whatever happens in Albany.
Albany is next. S9072A follows SB 253 closely. If it passes the Assembly and is signed, Scope 1 and 2 reporting would start in 2028. After the 9 November ruling on California's Scope 3 provision, expect the bill's Scope 3 section to be debated.
Collect once. Building-level data for LL97 and company-level Scope 1 and 2 for SB 253 come from the same meters and invoices.

Checklist

List your NYC buildings and check each against DOB's covered buildings list.
Confirm whether you meet SB 253's revenue threshold and do business in California.
Track S9072A / A4282 on nysenate.gov.
Keep meter- and invoice-level Scope 1 and 2 data that can serve both building and company reports.

How Breathe ESG helps

Breathe ESG keeps Scope 1 and 2 data with an audit trail back to the source invoice or meter read, so one dataset can feed company-level reporting. Book a 20-minute walkthrough.

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