Despite the rolling back of environmental policies due to President Trump’s political agenda, some states are moving forward on addressing climate change issues. As of April 10, several US states have introduced or passed climate disclosure rules, with California taking the lead in enacting the most comprehensive legislation. Most recently, New York’s Senate reintroduced two bills that would require climate disclosure rules similar to those adopted by California in 2023. In addition, a bill requiring greenhouse gas (GHG) emissions disclosures was introduced in Colorado in January.
The Trump administration’s stance on climate change has been marked by skepticism towards what is established climate science, and a strong focus on deregulating environmental policies in order to prioritize fossil fuel production and economic growth. President Trump has frequently doubted scientific consensus on climate change, and has withdrawn the US from the Paris Agreement, choosing instead to focus on promoting energy independence and minimizing what the administration views as the economic burdens of environmental regulations. This approach has generated considerable controversy and drawn criticism from environmental groups and climate scientists.
One of the strongest advocates for addressing the impact of climate change has been California, which enacted a suite of climate disclosure laws including Senate Bill 253 (SB 253), the “Climate Corporate Data Accountability Act,” which mandates companies with over $1 billion in annual revenue doing business in California must publicly disclose Scope 1, 2, and 3 GHG emissions. In 2026, the state will require reporting of Scopes 1 and 2 emissions, with Scope 3 required in 2027. Third-party assurance will be required over time with noncompliance resulting in penalties. California also introduced Senate Bill 261 (SB 261), the “Climate-Related Financial Risk Act, which requires companies with over $500 million in annual revenue doing business in California to biennially disclose their climate-related financial risks and mitigation efforts, aligned with TCFD, starting January 1, 2026. Noncompliance can result in penalties.
The recent climate disclosure legislation that has been introduced in other states is similar to California’s climate disclosure laws, which are still in litigation. Some of the most recent legislation includes:
New York
New York introduced two bills in January 2025 including Senate Bill 3456 (SB 3456), the Climate Corporate Data Accountability Act, which is similar to California’s SB 253, requiring companies with over $1 billion in annual revenue doing business in New York to annually disclose Scope 1 and 2 emissions starting in 2027 and Scope 3 emissions starting in 2028. The second, Senate Bill 3697 (SB 3697), the Climate-Related Financial Risk Reporting Bill, mirrors California’s SB 261 requiring companies with over $500 million in annual revenue doing business in New York to prepare biennial reports on climate-related financial risks, beginning in 2028.
Colorado
Colorado recently introduced (HB25-1119), “Concerning Requiring Certain Entities to Disclose Information Concerning Greenhouse Gas Emissions”, which aimed to require companies that do business in Colorado with over $1 billion in annual revenue to publicly disclose their GHG emissions (Scope 1, 2, and eventually Scope 3), starting in 2028 and 2029, respectively. It would require that disclosures be subject to independent verification and follow the Greenhouse Gas Protocol standards. Noncompliance could result in daily penalties up to $100,000. However, the bill was postponed indefinitely on February 27 and did not become law.
New Jersey
Senate Bill No. 4117, “Climate Corporate Data Accountability Act”, requires large businesses with $1 billion or more in revenue doing business in New Jersey to annually report and publicly disclose their GHG emissions (Scope 1, 2, and 3) starting within 3 to 5 years of enactment. It allows compliance via California’s similar law and imposes penalties for violations. The bill is currently in the Senate Budget and Appropriations Committee.
It is important to note that the US Securities and Exchange Commission (SEC) had proposed a framework for federal climate disclosure rules in March 2024. However, these rules faced legal challenges and the SEC voted to end its defense of these rules in March 2025. This development increases the significance of state-level initiatives in driving climate disclosure in the US.
It is important to note that the Trump administration issued an Executive Order “Protecting American Energy from State Overreach, which aims to limit state and local authority to regulate energy production and use. The order argues that state environmental and climate policies hinder domestic energy production and directs the Attorney General to challenge state laws deemed burdensome or unconstitutional, particularly those related to climate change, environmental, social, and governance (ESG), and carbon emissions. The goal is to prioritize federal authority and promote “American energy dominance.”
Conclusion
Despite federal rollbacks under the Trump Administration’s agenda, several US states are demonstrating a continued commitment to addressing climate change through the implementation of climate disclosure regulations. California has set a precedent with its comprehensive legislation, and states like New York and New Jersey are following suit with similar bills aimed at mandating corporate GHG emissions and climate-related financial risk disclosures. While Colorado’s recent bill was postponed, the trend indicates a growing state-level movement to fill the regulatory gap left by the diminished federal stance. The SEC’s decision to no longer defend its own climate disclosure rules further emphasizes the importance of these state-driven initiatives. However, the Trump administration’s Executive Order seeking to limit state authority over energy regulations presents a significant challenge to these efforts, potentially leading to legal battles and hindering the progress of state-level climate action. If your organization is looking for insights and assistance on how best to adapt to the rapidly changing regulatory landscape for climate disclosures and compliance, please contact Canopy Edge for an initial consultation.
