5 States Improve Greenhouse Gas Emissions Reporting

States are filling the gap for transparency and standardization of reporting on climate risks

April 21, 2025

Five states generating nearly one-third of U.S. economic output are implementing laws requiring detailed greenhouse gas emissions reporting, marking a significant advancement in corporate environmental transparency.

California, New York, Illinois, New Jersey, and Colorado—collectively representing US$6.6 trillion in gross domestic product—have established timelines for implementation:

  • California: Mandates take effect January 2026.
  • New York: Final regulations by December 31, 2026; Scope 1 & 2 reporting in 2027; Scope 3 by January 2028.
  • Illinois: Scope 1 & 2 emissions reporting in 2027; Scope 3 in 2028.
  • New Jersey: Companies with over $1 billion in revenue to report Scope 1 & 2 emissions within three years of enactment; Scope 3 within four years.
  • Colorado: Scope 1 & 2 reporting by January 2028; Scope 3 by January 2029.

The emissions categories include:

  • Scope 1: Direct emissions from company-owned or controlled sources.
  • Scope 2: Indirect emissions from purchased electricity, steam, heating, and cooling.
  • Scope 3: Value chain emissions throughout a company’s operations, including supplier emissions.

“This coordinated push represents a significant advancement in corporate environmental transparency and sustainability requirements,” report Brad Molotsky and Duane Morris, attorneys active in helping organizations execute sustainability programs. “They also ensure that large corporations, as well as small- to medium-sized enterprises, will be accountable for their environmental impacts.”

Steve Ashkin of The Ashkin Group and co-chair of ISSA’s Sustainability Committee added, “This wave of disclosure requirements is a pivotal moment for businesses of all sizes, including those in the professional cleaning industry. ISSA members, whether directly reporting or supplying to larger companies, must now begin collecting environmental data to ensure compliance. This will also help them leverage sustainability initiatives as a strategic advantage.”

According to Ashkin, the most important takeaway is that “while the federal government may be discontinuing its requirements for transparency and standardization of reporting on climate risks, states are filling the gap. They are establishing their own mandatory reporting requirements, which will likely spread to other states around the country.”

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