Raising Capital From NYC’s Pension Funds?
What the Net Zero Plans Mean for Asset Managers
10/28/20262 min read
Three of New York City’s public pension funds (NYCERS, TRS and BERS) adopted Net Zero Implementation Plans in 2023, committing to net zero emissions across their portfolios by 2040. The Plans are board policy, not formal regulation. The details come from directives and guidance issued by the Comptroller’s Bureau of Asset Management (BAM), which reviews every manager’s plan.
For asset managers, the practical point is simple: a credible climate plan is now part of winning and keeping an NYC mandate.
What BAM expects from managers
A net zero goal, science-based targets or an acceptable alternative approach that covers the assets you manage for the Systems, including Scope 1 and 2 and material Scope 3 emissions.
A systematic stewardship approach: a focus list of high-emitting holdings, a quantified engagement target, ongoing engagement on climate practices such as governance, transition plans and capital expenditure alignment, plus monitoring and escalation.
Climate risk and opportunity built into investment decisions, including due diligence and portfolio management.
Annual reporting on your engagement activity. BAM has said it is finalizing detailed guidance on this.
BAM does not ask for a single approach. It weighs asset class, strategy, and whether you are a control or non-control investor. It also says managers should not exclude investments just to meet these expectations unless doing so is consistent with their fiduciary duty and the fund’s objectives.
Why this matters now
In 2025, all 49 public markets managers submitted plans by the June 30 deadline. Forty-six met the Systems’ expectations. Three did not, and the Comptroller recommended that the boards put those mandates out to bid.
Private markets are included. Funds receiving new commitments since mid-2025 are expected to submit plans as well.
In January 2026, BAM updated its due diligence questionnaire with more detailed climate questions, so expect closer scrutiny of your approach before you are approved.
Compliance isn't optional; it is required!
How ESGA can help
Meeting these expectations takes real work, and it should not pull your investment team away from the portfolio. ESGA works alongside your team, with ESG specialists who understand the investment life cycle, to:
Assess your current approach against BAM’s expectations and the frameworks it points to, including SBTi, Net Zero Investment Framework, Net-Zero Asset Owner Alliance, and the Private Markets Decarbonization Roadmap.
Build a customized plan using the framework that best fits your fund and asset class, including private credit and other private markets.
Set up measurement, engagement tracking, and reporting, supported by technology, so progress is documented and easy to update.
Prepare annual reports that update BAM on your engagement activity.
Our approach is built on identifying risk and opportunity, not advocacy. The goal is a plan you can stand behind with investors and fiduciaries.
Next step
Contact ESGA to schedule a readiness review before your next NYC request for a mandate or allocation.
About the author
Joe Holman founded ESG Administration LLC. With over 25 years of experience in financial services, fund administration, and operational consulting, he brings a rare combination of deep industry expertise and forward-looking ESG insight to the alternative investment landscape.
For more information on this topic or climate reporting, contact ESGA at joe.holman@esgadmin.com.
Sources (NYC Comptroller):
NYCERS Annual Climate Report FY2025
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