As the US Environmental Protection Agency (EPA) rolls back greenhouse gas (GHG) laws, rules, and regulations consistent with Trump Administration priorities, several states are advancing legislation to create their own GHG emissions reporting frameworks. While some of these initiatives generally mirror California’s climate disclosure requirements, this new state-led regulatory landscape is creating a state-by-state patchwork that businesses must now monitor.

Federal Rollback

Beginning with President Trump’s Executive Order 14154, “Unleashing American Energy” (January 20, 2025), the Trump Administration has made clear that it opposes any laws—federal or state—addressing the causes or impacts of climate change. For example:

• Executive Order 14154 revoked a suite of existing climate-related presidential executive orders and abolished offices, programs, and funding established pursuant to them.
• The Securities and Exchange Commission ended its in-court defense of corporate climate disclosure rules, which were adopted on March 6, 2024. Consequently, the climate disclosure rules will not go into effect.
• On April 8, 2025, President Trump signed Executive Order 14260, “Protecting American Energy From State Overreach,” which aims to stop the enforcement of state laws addressing climate change on the ground that they are unconstitutional, unenforceable, and preempted by federal law.
• Most recently, the EPA finalized a rule on February 12, 2026, overturning its own “Endangerment Finding”—a finding that allowed EPA to regulate GHGs as pollutants under the Clean Air Act and underpins virtually all federal laws regulating GHGs.

Terminology

Generally speaking, GHG reporting laws focus on Scope 1, 2, and 3 emissions. For the uninitiated, the different “Scopes” are as follows:

• Scope 1 Emissions: These are direct emissions from sources that a company owns or controls (think, stack emissions from an industrial facility). 
• Scope 2 Emissions: These are indirect emissions associated with the generation of purchased electricity, steam, heating, and cooling that the company consumes. While the business does not produce these emissions directly, they are a consequence of the energy the company uses. 
• Scope 3 Emissions: This category encompasses all other indirect emissions that occur upstream and downstream along a business’s supply chain and, in some instances, can contribute far more to a business’ carbon footprint than Scope 1 or 2 emissions combined. Scope 3 emissions can include downstream production, shipping, waste, disposal, employee transportation, and the like.

State Patchwork

GHG emissions reporting legislation has been enacted and/or introduced in California, Colorado, Illinois, Maryland, Minnesota, New Jersey, New York, and Washington.  (NB: This article does not discuss California. Our firm’s coverage of California’s emissions regulations can be found in this detailed overview and this recent update.)  A brief summary of legislation currently in effect, proposed, and attempted is summarized below: