The European Commission (“Commission”) has launched a four-week feedback period — open until June 3, 2026 — on a draft delegated act to revise the European Sustainability Reporting Standards (“ESRS 2.0”). Ultimately, EU companies in scope of the EU’s Corporate Sustainability Reporting Directive (“CSRD”) will have to draft their annual
Continue Reading European Commission Publishes “ESRS 2.0” for Public Consultation: Draft Closely Follows EFRAG’s Technical Advice with Additional Simplifications for CompaniesDisclosure Requirements
Key Takeaways from the California Air Resources Board’s Public Workshop on the California Corporate Greenhouse Gas Reporting Program
On March 23, 2026, the California Air Resources Board (“CARB”) held a public, “pre-rulemaking” workshop to introduce regulatory approaches for reporting greenhouse gas (“GHG”) emissions under the Climate Corporate Data Accountability Act (“SB 253”). SB 253 requires U.S.-based entities with more than $1 billion in annual revenue doing business in…
Continue Reading Key Takeaways from the California Air Resources Board’s Public Workshop on the California Corporate Greenhouse Gas Reporting ProgramCalifornia Climate Disclosure Laws: CARB Draft Regulations Clarify Fees, Deadlines, and Applicability
California regulators tasked with implementing and enforcing the state’s two landmark climate disclosure laws released draft regulatory text on December 9, 2025, providing additional insight on key issues, including initial deadlines for reporting greenhouse gas (“GHG”) emissions and details on how regulators will determine annual fees. The release of the…
Continue Reading California Climate Disclosure Laws: CARB Draft Regulations Clarify Fees, Deadlines, and ApplicabilityTask Force for Corporate Action Transparency Launches New Frameworks for Climate Action Reporting
In the lead-up to COP30 in Brazil, the newly created Task Force for Corporate Action Transparency (TCAT) launched two comprehensive greenhouse gas reporting frameworks designed to fill an important gap in how companies measure, report on, and verify their corporate climate actions. TCAT leadership has indicated that the frameworks will…
Continue Reading Task Force for Corporate Action Transparency Launches New Frameworks for Climate Action ReportingEPA Proposes Changes to TSCA PFAS Reporting Rule
On November 10, 2025, EPA released a proposed rule under the Toxic Substances Control Act (“TSCA”), proposing to amend its reporting requirements relating to per- and polyfluoroalkyl substances (“PFAS”). The original rule, promulgated in 2023, led to concerns by some regulated entities that it would be difficult to collect the…
Continue Reading EPA Proposes Changes to TSCA PFAS Reporting RuleState Greenhouse Gas Reporting Programs: New York’s Proposed Mandatory Reporting Program and California’s Existing Program
While the Environmental Protection Agency (“EPA”) is proposing to amend the federal Greenhouse Gas Reporting Program (“GHGRP”) to remove reporting requirements for nearly all sources, it remains important for companies to track developments and manage their compliance obligations with existing and emerging state GHG reporting programs. Several states, such as…
Continue Reading State Greenhouse Gas Reporting Programs: New York’s Proposed Mandatory Reporting Program and California’s Existing ProgramKey Takeaways From California Air Resources Board’s Public Workshop on Implementing California Climate Disclosure Laws SB 253 and SB 261
On May 29, the California Air Resources Board (“CARB”) held a virtual public workshop to discuss forthcoming regulations to implement SB 253 and SB 261, landmark California laws that require many corporate entities to disclose their greenhouse gas (“GHG”) emissions and climate-related financial risk. CARB affirmed the existing statutory deadlines…
Continue Reading Key Takeaways From California Air Resources Board’s Public Workshop on Implementing California Climate Disclosure Laws SB 253 and SB 261California Legislature Passes Landmark Climate Disclosure Laws: Spotlight on SB 253
Last week, the California Legislature passed two bills comprising the core of a landmark “Climate Accountability Package.” Together, the two bills will impose extensive new climate-related disclosure obligations on thousands of U.S. public and private companies with operations in California. Senate Bill 253 (SB 253) would require companies with greater than $1 billion in annual revenues to file annual reports publicly disclosing their Scope 1, 2 and 3 greenhouse gas (GHG) emissions. Senate Bill 261 (SB 261) would require companies with greater than $500 million in annual revenues to prepare biennial reports disclosing climate-related financial risk and describing measures adopted to mitigate and adapt to that risk.
Yesterday afternoon during an appearance at Climate Week NYC, Governor Newsom told the audience emphatically, “of course I will sign those bills.” When he does, many more companies will be required to improve the accuracy, completeness and rigor of their GHG reporting and climate risk disclosures. Because of the complexity of GHG reporting, we have focused the remainder of this post on SB 253. Please see our separate post on SB 261 here.
Continue Reading California Legislature Passes Landmark Climate Disclosure Laws: Spotlight on SB 253California Legislature Passes Landmark Climate Disclosure Laws: Spotlight on SB 261
Last week, the California Legislature passed two bills as part of the state’s landmark “Climate Accountability Package.” If signed by Governor Newsom as anticipated, the two laws—Senate Bill 253 (SB 253) and Senate Bill 261 (SB 261)—will usher in significant climate-related disclosure requirements for thousands of U.S. public and private companies that do business in California.
SB 253 and SB 261 mark the most extensive emissions- and climate-disclosure laws enacted in the United States to date. SB 253 requires companies with greater than $1 billion in annual revenues to file annual reports publicly disclosing their direct, indirect, and supply chain greenhouse gas (GHG) emissions, verified by an independent and experienced third-party provider. SB 261 requires companies with $500 million in annual revenues to prepare biennial reports disclosing climate-related financial risk and measures they have adopted to reduce and adapt to that risk, with the first report due by January 1, 2026.
This post focuses on SB 261’s climate-related financial risk disclosure requirements. You can find our post on SB 253’s GHG emissions reporting requirements here.
Continue Reading California Legislature Passes Landmark Climate Disclosure Laws: Spotlight on SB 261Corporate Reporting in the UK: The International Sustainability Standards Board
On 26 June 2023, the International Sustainability Standards Board (“ISSB”) published its inaugural International Financial Reporting Standards Sustainability Disclosure Standards (the “ISSB Standards”) (read our previous blog post on this here). In August 2023, the UK Financial Conduct Authority (“FCA”) published Primary Market Bulletin 45, confirming its intentions to update its climate-related disclosures for listed companies under the Listing Rules (see LR 9.8.6 R (8) and LR 14.3.27 R) to reference UK-endorsed ISSB Standards.
Continue Reading Corporate Reporting in the UK: The International Sustainability Standards Board