On February 3, 2025, New Jersey introduced S4117, also known as the New Jersey Climate Corporate Data Accountability Act, and referred it to the Senate Environment and Energy Committee.
If enacted, the bill would require large companies doing business in New Jersey to annually disclose their greenhouse gas emissions, aligning the state with emerging disclosure frameworks in California, New York, and Colorado.
For companies operating in New Jersey, S4117 signals a major shift toward mandatory climate transparency and standardized emissions reporting.
What does S4117 require?
The New Jersey Climate Corporate Data Accountability Act (S4117) would require companies with more than $1 billion in annual global revenue to report their greenhouse gas emissions.
Key requirements include:
- Annual disclosure of Scope 1, 2, and 3 emissions
- Reporting aligned with the Greenhouse Gas Protocol Corporate Accounting and Reporting Standard
- Submission of data to the New Jersey Department of Environmental Protection (DEP) and a public platform
- Independent third-party verification of emissions data
The bill is designed to align with similar legislation in other states, helping create consistency for companies operating across jurisdictions.
What are Scope 1, 2, and 3 emissions?
- Scope 1 refers to direct emissions from sources the company owns or controls
- Scope 2 refers to indirect emissions from purchased electricity, steam, heating, and cooling
- Scope 3 refers to all other indirect emissions from the value chain
Which companies does the bill apply to?
S4117 applies to:
- Companies with over $1 billion in annual global revenue
- Any company doing business in New Jersey, regardless of headquarters location
If your organization meets both criteria, it would likely be required to report greenhouse gas emissions under the New Jersey Climate Corporate Data Accountability Act.
What is the timeline for implementation?
If passed, New Jersey’s bill could require reporting to begin as early as 2028 for Scope 1 and 2 emissions.
Here’s the specific timeline:
Three years after the effective date: In-scope business entities must begin providing annual reports to the New Jersey Department of Environmental Protection (DEP) and a selected nonprofit organization.
Four years after passage: New Jersey’s proposed legislation requires companies with annual revenue in excess of $1 billion to report Scope 1 and Scope 2 emissions within four years of passage. Entities must publicly disclose Scope 1 and 2 emissions.
Five years after passage: If passed, New Jersey’s bill would require organizations to disclose Scope 1, 2, and 3 emissions for the prior fiscal year starting three years after the effective date of the act. Entities must publicly disclose Scope 3 emissions within five years.
How is the bill similar to legislation in other states?
California (SB 253)
Enacted in 2023, SB 253 requires companies with over $1 billion in annual revenue that do business in California to report their greenhouse gas emissions.
- Scope 1 and 2 reporting begins in 2026
- Scope 3 reporting follows in 2027
- Disclosures must be independently verified and submitted to a public registry
This law is widely seen as the first comprehensive, mandatory Scope 1–3 disclosure regime in the US, and it applies to thousands of companies globally due to California’s market reach.
New York (proposed legislation)
New York is developing similar legislation modeled on California’s approach.
- Proposed bills would require full Scope 1, 2, and 3 emissions disclosure
- The state is expected to finalize implementing regulations by the end of 2026
If enacted, New York would reinforce a multi-state reporting standard aligned with California.
Colorado (proposed legislation)
Colorado has introduced climate disclosure proposals with a phased timeline:
- Scope 1 and 2 reporting expected from 2028
- Scope 3 reporting expected from 2029
The structure mirrors California’s framework but introduces a more gradual rollout.
The New Jersey bill aims to minimize duplication of effort by allowing companies to submit reports prepared for other national and international reporting requirements. The bill allows companies to use emissions reports generated for California’s similar Climate Corporate Data Accountability Act to comply with New Jersey’s requirements.
What is the bill’s current status?
The NJ bill is currently with the Senate Environment and Energy Committee. It must be voted on and approved by committee, passed by the New Jersey Senate, approved by the state legislature, and enacted before becoming law.
Will there be penalties for non-compliance?
The bill includes escalating fines for non-compliance, starting at $10,000 for the first offense and increasing to $50,000 for subsequent offenses. The New Jersey Department of Environmental Protection would be authorized to collect fees from all reporting entities and could issue fines of up to $50,000 per day for failure to report. Each day of continued violation constitutes a separate offense.
How can in-scope companies prepare?
In-scope companies should take a proactive approach and begin preparing ahead of the legislation’s passage:
1. Identify if you’re subject: Review your consolidated global revenue and New Jersey business operations.
2. Map your emissions: Start tracking Scope 1, 2, and 3 emissions across your operations and value chain.
3. Build data systems: Establish processes aligned with the Greenhouse Gas Protocol to capture emissions data with clear audit trails.
4. Prepare for verification: Independent third-party assurance is required, so ensure your data is verification-ready.
5. Align with multi-state requirements: If you operate in California, Colorado, or New York, build systems that satisfy multiple state frameworks simultaneously.
6. Monitor the legislative process: Track the bill’s progress through the Senate Environment and Energy Committee, appropriations committee, and senate budget process.
How Sweep can help
Sweep helps reporting entities streamline greenhouse gas emissions tracking across Scope 1, 2, and 3:
- Automate data collection using the Greenhouse Gas Protocol Corporate Accounting and Reporting Standard
- Maintain verification-ready records for independent third-party assurance requirements
- Track compliance across New Jersey, California, Colorado, New York, and international regulations
- Reduce duplication by creating reports that satisfy multiple state frameworks
- Prepare for phased reporting with audit trails and public disclosure-ready formats
As New Jersey and other states create climate corporate accountability frameworks, companies that invest in robust data management today will lead tomorrow.
