The Fashion Act Is Here. Now Comes the Test.

Jun 19

It’s official. The New York Fashion Act goes into effect on June 19. Not a proposal, not a rallying point — actual law. If you’re a fashion company making over $100 million and doing business in New York, your operations just became legally accountable in a way they’ve never been before.

A lot of people have been waiting for this — organizers, lawyers, brands trying to do the right thing, and honestly, a lot of skeptics too. The bill’s been around for a while, and depending on who you talk to, it’s either long overdue or wildly ambitious or not enough. But what matters now is it’s real. It passed. It’s active. And it’s going to start changing things — whether the industry’s ready or not.

This isn’t going to be a recap of the legislation. If you work in this space, you already know what’s in it. What I care about — and what this post is really about — is what happens now. What actually shifts, who’s affected, how brands might respond, and what all of this signals beyond fashion. Because I don’t think this law is the endpoint. I think it’s the opening move.

What Shifts Now — Practically, Financially, Culturally

The biggest shift isn’t visual. It’s structural. Most people won’t notice anything right away, but for the companies who are actually affected, the landscape just changed.

Practically, the clock starts ticking. Tier 1 supplier mapping has to be done within a year. That means brands now need to know — and name — the factories where their products are assembled. Not just internally, but publicly. No more vague language about “partners” or “manufacturing hubs.” It’s names, addresses, headcounts, wage data. And that’s just Tier 1. Tier 2, 3, and 4 come next — textile mills, yarn suppliers, farms. This isn’t a one-time audit. It’s an ongoing obligation.

Financially, brands will have to reallocate money toward actual compliance — not just communications. Legal teams, ESG leads, supply chain ops — everyone’s going to feel this. Some companies will absorb the cost. Others will outsource it. And some will probably cut corners and hope no one’s looking (we all know the ones). But there’s now a very real price for noncompliance: up to 2% of global revenue. That’s not symbolic. That’s enough to shake up a boardroom.

Culturally, I think this could be a reset moment — not for aesthetics, but for how power operates in fashion. It shifts the tone from “we care” to “we’re liable.” The sustainability page on a brand’s website just became a lot riskier to write. That language now has to match what’s verifiable in open data. There’s less room for storytelling and more pressure for proof. That doesn’t mean all greenwashing disappears, but it’s going to get harder to dress it up.

So no, nothing flashy happens on June 19. There’s no big reveal. But something shifts underneath — and the effects will build over time.

Who’s Quietly Panicking

Many brands aren’t saying much right now, and that’s not surprising. No one wants to draw attention to a law they might not be ready for. But behind the scenes, i’m sure you can feel the scramble.

The ones sweating the most are probably the ones whose supply chains rely on opacity as a business model. Fast fashion players are the obvious example — the speed, the volume, the price points. There’s just no way to hit those margins while fully tracking and managing labor, emissions, and chemical use across four tiers of production. They’re built to move product, not map factories.

But it’s not just fast fashion. Luxury brands aren’t immune either — especially the ones that have historically relied on a kind of curated mystery. The ones that lean on heritage and craftsmanship but don’t actually disclose much beyond the final stitch (cough, cough, Dior). Under this law, they’ll have to open the curtain… not all of them are ready to do that.

And then there’s the private label giants — the Amazons, the Targets, the multi-brand retailers whose in-house lines quietly rake in billions. A lot of those products are made through third-party relationships with limited visibility, and now those relationships are under a microscope.

What’s interesting is that some of the “sustainability-forward” brands might also be uncomfortable. Not because they aren’t doing the work — but because now the work has to be verified, structured, and published. It’s one thing to put out a beautiful report once a year with select highlights. It’s another to submit raw data, every year, in a machine-readable format, knowing it can and will be scraped, compared, and criticized. It’s a lot of work!

So while the public tone is pretty calm, there’s definitely a shift happening behind closed doors. Compliance meetings. Legal reviews. Quiet attempts to figure out what “risk-based approach” really means — and how much wiggle room it allows.

What Enforcement Actually Looks Like in a Messy Supply Chain

This is where things get complicated. It’s one thing to write a law. It’s another to enforce it across a global industry that touches everything from farms in India to spinning mills in Turkey to sewing floors in Vietnam. The fashion supply chain wasn’t built to be clean. It was built to be fast, cheap, and layered. That makes enforcement messy by design.

The New York Attorney General’s office is officially in charge. They can investigate, fine, publish lists of noncompliant brands — and those tools matter. But the truth is, the AG can’t monitor every single brand, supplier, and dataset. That’s not a dig — that’s just how state agencies work. The power of enforcement here is going to depend a lot on who else is paying attention.

That’s where open data comes in. Because once the reports go live — with supplier names, wage data, emissions, water use — it’s not just regulators who can act. It’s researchers. Journalists. Labor organizers. Investors. Customers. NGOs. Anyone who knows how to work with data can start piecing things together. You don’t need a badge to call out a gap in wage disclosures or a brand that keeps saying they’re sustainable while quietly failing to meet basic compliance.

And that’s probably the most effective kind of pressure — public, decentralized, persistent. You don’t need every brand to be fined. You just need a few big ones to be flagged, and suddenly everyone else is on alert.

But it’s not going to be clean. Some companies will comply quickly and quietly. Others will stall or give the bare minimum. Some will try to contract their way around responsibility — shifting liability to suppliers, hiding behind intermediaries, or using creative definitions of “significant volume.”

It’s going to take time to see what real enforcement looks like. And it’ll probably look different for each brand, depending on how visible, profitable, or exposed they already are.

The Loopholes That Will Be Exploited

No legislation is airtight. And this one, for all its strength, still leaves room to maneuver — especially for companies with the legal teams and PR resources to make compliance look cleaner than it really is.

The most obvious opening is the “risk-based approach” language. It’s in the law for practical reasons — it gives brands some flexibility to prioritize higher-impact areas first. But in practice, it can also be used to justify inaction. If a brand doesn’t want to map certain suppliers, or finds some emissions too hard to track, they can argue that those fall lower on their risk scale. Without strong regulatory follow-up, “risk-based” can quietly become “optional.”

Another one: primary data thresholds. The law gives brands until year four to start collecting primary emissions data from their Tier 2 and 3 suppliers — which is good in theory. But primary data is hard to collect when you’re dealing with shared facilities, vague ownership structures, or suppliers who don’t have the tech to measure things properly. Some brands will meet that challenge. Others will likely pad their numbers with modeled estimates and hope it passes as close enough.

Wage reporting is another soft spot. Brands are required to report mean wages at Tier 1 sites and compare them to local minimums and living wage benchmarks. But “mean wage” is a tricky metric. You can skew it higher by keeping part-time workers off the books, or by averaging a few higher-paid roles with a much larger base of underpaid ones. It’s not hard to make the numbers look better than they are, especially in countries where wage records aren’t standardized.

Then there’s the question of liability workarounds. The law makes brands jointly and severally liable for unpaid wages in Tier 1 — which is huge. But it won’t stop some companies from writing contracts that try to push responsibility back down the chain. It might not hold up in court, but that doesn’t mean they won’t try. Legal evasion isn’t just about winning — sometimes it’s about delaying.

Then there’s the 18-month compliance window. If a company is found out of compliance, they get a year and a half to fix it before any fines are issued. On paper, that seems fair — it gives brands time to get things in order. But in reality, it’s probably going to get taken advantage of. There are brands that have known about this bill for years and still waited until the last possible minute to move. Some never planned to act unless they were forced. And now they’ve got another buffer to hide behind. If there’s no pressure before that 18-month mark, what’s to stop companies from treating it like a grace period they can coast through?

None of this is surprising. This is how companies operate when they’re under pressure: they look for gray zones, soft spots, and language they can interpret in their favor. The point of calling it out isn’t to say the law doesn’t matter — it’s to say this is where the fight moves next.

What Insiders and Watchdogs Will Be Watching

Now that this is real, the energy shifts. It’s no longer about arguing over whether the law is too ambitious — it’s about watching who takes it seriously, and who’s just trying to look like they are.

The first thing people are going to be watching is the year-one reports. That’s where the real tone will get set. Who actually names their suppliers? Who gives clear, full answers — and who pads things with vague language and partial numbers? Who publishes it openly, and who buries it in some unreadable PDF at the bottom of a footer link? All of that is going to matter more than the press release.

Wage data is going to be another focus point — not just the numbers themselves, but how they’re framed. Everyone’s going to be watching the gap between minimum wage and living wage. And even if those figures pass legal muster, they still open brands up to public critique. Especially if the storytelling doesn’t match the data.

There’s also going to be a lot of attention on how emissions are tracked, especially Scope 3. It’s always been the hardest to pin down, and now that brands have to start using primary data in the next few years, you’ll start to see a split between companies that invest in real tracking and ones that cling to modeled estimates for as long as they can.

People will also be watching how brands respond to enforcement — if they get flagged for something, do they handle it transparently and fix it? Or do they go quiet and lawyer up? A lot of brands have spent years building public trust around their sustainability messaging, and how they respond under pressure will tell you whether that trust was built on anything real.

And finally — people are going to be watching the verification process itself. Not all third-party verifiers are created equal, and the Department of State is now responsible for accrediting them. If the wrong firms slip through — the ones who’ve made a business out of passing everything with a green stamp — that could undermine the whole thing. So even the enforcement mechanisms are going to be watched closely.

This Isn’t Just About Fashion

The Fashion Act might be industry-specific, but it’s not just a fashion story. It’s a regulatory blueprint — and other industries are definitely paying attention.

Because once something like this passes in one sector, in one place, the thinking starts to spread. If New York can demand this kind of transparency and accountability from fashion brands, what’s stopping California from doing the same for beauty or electronics? What happens when people start asking why we know more about where our jeans come from than where our lipstick or iPhones are made?

There’s also the investor angle. As more states (or countries) start building laws like this, it changes how compliance gets priced into risk. Suddenly, supply chain mapping and emissions tracking aren’t “nice to have” — they’re tied to legal exposure. And that shifts ESG from being a branding tool to being a baseline. The conversation moves from: “What’s our sustainability story?” to “What’s our liability exposure?” That’s a very different boardroom conversation.

And it’s not just investors and regulators — it’s consumers too. People are getting used to seeing behind the curtain. Once open data becomes normalized in one category, it raises expectations everywhere else. If fashion can publish names, locations, and wages, why can't tech? Why can some industries get away with saying "supply chain complexity" like it's a magic shield?

This law wasn’t designed to fix every industry — but the logic of it is contagious. Traceability, accountability, open data, clear targets, public reporting — those tools work beyond clothing. And if they stick here, you can bet they’ll show up elsewhere.

Does This Shift Power, or Just Accountability?

This is the part I keep coming back to. Because while the law is about accountability — tracking, reporting, reducing, disclosing — the bigger question is: does it actually shift power?

Accountability is important. It creates boundaries, consequences, pressure. It forces companies to clean up the parts of their business they used to keep buried. That matters. But power is something else. Power is about who gets to set the terms. Who gets to make decisions. Who gets protected when things go wrong.

And most of that still hasn’t changed.

The brands still hold the capital. The supply chain is still structured to keep risk at the bottom and profit at the top. And even with this law, a lot of the responsibility still falls on the same people it always has — suppliers, workers, local communities, under-resourced NGOs. Now they have more legal backing, yes. But they’re still not the ones calling the shots.

That said… I don’t think this law is toothless. Because while it may not flip the entire structure, it does make it harder for power to operate invisibly. It forces visibility. It turns legal systems into pressure points. It gives people new tools to track and respond and call things out with proof, not just outrage.

And maybe that’s where the shift starts — not with who holds the power, but with how easy it is to see it, name it, and challenge it.

This isn’t a revolution. But it’s also not performative. It’s policy. And that’s a harder thing to ignore.

Final Thought

So yeah, the Fashion Act is officially in effect. After years of proposals, edits, panel talks, and delays — it’s finally real. Now we get to see what that actually means.

Some brands will treat it like a checklist. Others will try to coast through the margins. A few might actually lead. And a lot of people — myself included — will be watching to see which is which.

This isn’t the kind of thing that changes the industry overnight. But it does set something in motion. It puts the weight of law behind a set of expectations that, until now, were mostly vibes.

It’s not perfect. It’s probably going to get messy. But it’s a start. And for once, it’s not just about what companies say — it’s about what they do, what they report, and whether it holds up when the numbers hit the page.

Aman Gill