Washington State Disclosure of Greenhouse Gas Emissions SB-6092 2023-2024

The Washington Senate Bill 6092 (SB 6092), known as the Washington Climate Corporate Data Accountability Act, introduces greenhouse gas (GHG) disclosure requirements for large companies operating within the state. The bill would mandate businesses with over $1 million in annual revenue and conducting substantial activities in Washington to report their GHG emissions to the Washington State Department of Ecology (WSDE).

The reporting requirements will primarily focus on Scope 1, 2, and 3 emissions. Scope 1 emissions include direct emissions from activities and sources under an entity’s control, such as emissions from company-owned vehicles or on-site natural gas turbines. Scope 2 emissions refer to indirect emissions resulting from the consumption of energy purchased, like electricity or steam from a utility provider. Scope 3 emissions also represent indirect emissions but specifically include those that occur across a company’s value chain and are not captured under Scope 1 or 2. These can encompass emissions from suppliers, product transportation, employee commuting, or end-of-life product disposal. Because Scope 3 emissions rely heavily on third-party data and span a wide range of activities, they are significantly more difficult for companies to track and verify.

What is the status of the Bill?

Washington SB 6092 was first introduced in January 2024 and passed the Washington Senate a month later. As of March 7, 2024, the bill was sent back to the Senate Rules Committee for a third reading by the House. The bill directs the WSDE to research and develop policy recommendations based on the Securities and Exchange Commission’s (SEC) climate-related disclosure rule and to provide guidance on how Washington can align its reporting requirements. However, the SEC’s recent withdrawal of its climate disclosure rules has shifted greater responsibility to states like Washington to lead on climate transparency. WSDE had intended to align SB 6092 with the SEC framework to minimize duplicative reporting for companies. In light of the federal regulatory uncertainty, WSDE may increasingly look to California’s SB 253, also known as the Climate Corporate Data Accountability Act (CCDAA),  and internationally recognized frameworks to inform its policy development and implementation timeline.

The original deadline for this guidance was January 1^st of 2025, but it has since been extended to July 1, 2025, under a second substitute. If the bill is finalized in July of 2025, Washington would become the second state, after California, to mandate economy-wide disclosure of all GHG emissions for large businesses.

What Does this Mean for Companies in Washington State?

​Currently in Washington, businesses that emit 10,000 metric tons or more of CO₂ equivalent greenhouse gases annually are required to report their emissions to the Department of Ecology. This mandate applies to both facilities and fuel suppliers. Additionally, entities emitting 25,000 metric tons or more are subject to the Cap-and-Invest Program under the Climate Commitment Act, which includes third-party verification requirements starting with 2023 emissions data.

Companies doing business in Washington State can expect the following requirements:

• Report Scope 1 and Scope 2 emissions for the 2025 calendar year by October 1, 2026, and each year thereafter.
• Report Scope 3 emissions for the 2026 calendar year by October 1, 2027, in addition to the Scope 1 and Scope 2 emissions.
• Each report will require third-party verification to ensure completeness and accuracy.

Once the bill passes, WDSE is expected to develop and publish a web-based platform to make the emissions reports easily accessible to the public for review and comment. However, the bill may not go into effect until the California Air Resources Board (CARB) has completed its rulemaking process, following a related California ruling on corporate emissions reporting. Both the California Act and Washington SB 6092 use the same foundational emissions accounting standards for companies to develop one set of emissions data that can be applied in both states, reducing redundancy. Washington’s SB 6092 aims to complement, rather than duplicate, the framework laid out within California’s Act.

How to Prepare:

Companies located in or operating in Washington State should assess whether they will be subject to Washington’s SB 6092 and begin reviewing their climate strategies and existing reporting policies. It may be beneficial to consider implementing or enhancing systems to track GHG emissions to streamline future compliance. While Washington’s SB 6092 has not yet been officially enacted, the passage of other climate disclosure laws, such as the CCDAA, indicates a continued trend toward increased climate-related regulations at the state level, even as the new administration threatens to relax its rules. The good news is that larger corporations already preparing for CCDAA may not need an entirely new system for Washington, but rather an expansion of their current processes. However, companies operating in both California and Washington may still face challenges, particularly when it comes to accounting for Scope 3 emissions, due to the difficulties in collecting the necessary data to calculate them. This is why it is important for companies to start the process sooner rather than later.

How ALL4 Can Help:

ALL4’s sustainability experts are prepared to support companies as they assess and respond to Washington’s SB 6092. Our team can assist in aligning climate strategies with anticipated reporting requirements, developing processes to track Scope 1, 2, and 3 emissions, and expanding existing programs to ensure regional compliance. Whether a company is already preparing for similar regulations or is evaluating for the first time, ALL4 provides tailored support to meet disclosure obligations and advance long-term sustainability goals.

For inquiries about how ALL4 can support your organization in preparing for Washington’s SB 6092 and broader climate disclosure requirements, please contact Cambre Codington at ccodington@all4inc.com.