Summary: US Climate Disclosure Mandates


Updated as of April 21, 2025

California SB 253: 

Climate Corporate Data Accountability Act

California SB 261:

Greenhouse Gases; Climate Related Financial Risk

California AB 1305:

Voluntary Carbon Market Disclosures

 

Status:

Enacted October 7, 2023

Regulations expected July 1, 2025

Status:

Enacted October 7, 2023

Status:

Enacted October 7, 2023

Companies effected:

United States entities with annual revenue exceeding $1 billion and doing business in California

 

Companies effected:

United States entities with annual revenue exceeding $500 million and doing business in California

Companies effected:

Sell Side - Business entity that is marketing or selling carbon offsets within CA

Buy Side – Business entity that operates in CA, purchases or uses carbon offsets sold in CA and makes decarbonization claims about the achievement of emissions reductions or net zero emissions

Emissions Marketing Claims – Business entity that operates in CA and makes decarbonization claims within CA about significant emissions reductions or net zero emissions

Emissions Disclosures:

Detailed report of Scope 1, Scope 2 and Scope 3 corporate emissions

 

Emissions Disclosures:

Not required

Emissions Disclosures:

Not required

Other Disclosures:

N/A

Other Disclosures:

Detailed report on climate related financial risks, and measures it has taken to reduce these risks

 

Other Disclosures:

Sell Side – Disclose following information about carbon offsets used: project information, details of accountability measure for incomplete projects, and data and calculation methods needed to reproduce emissions reduction calculations

Buy Side – Disclose following information about carbon offsets purchased: seller’s name, registry, project ID number, project name, emissions reduction type and location, protocol used to estimate reductions and whether 3rd party verification exists

Emissions Marketing Claims – Entity making emissions reduction claims must disclose information about claim validity, interim progress and whether 3rd party verification exists

Compliance Deadlines:

Beginning in 2026, only Scope 1 and 2 emissions must be reported.  Beginning in 2027, Scope 3 emissions must be reported on a date specified by the California Air Resources Board (CARB)

Compliance Deadlines:

Beginning in 2026

Compliance Deadline:

January 1, 2025

Reporting standard:

Greenhouse Gas Protocol (GHG), including Corporate Standard and Value Chain

 

Reporting standard:

Task Force on Climate-related Financial Disclosures or similar, including the International Financial Reporting Standards Sustainability Disclosure Standards, as issued by the International Sustainability Standards Board

Reporting standard:

N/A

Assurance:

2026 Limited Assurance on Scope 1 and 2

2030 Reasonable Assurance on Scope 1 and 2 and Limited Assurance on Scope 3

Assurance:

Not required

Assurance:

Not required

Reporting method:

Digital platform run by CARB or an Emissions Reporting Organization (ERO) and accessible to the public

Reporting method:

Submit to California Climate-Related Risk Disclosure Advisory Group and post on reporting entity public website

Reporting method:

Post to reporting entity’s public website

Reporting frequency:

Annual

Reporting frequency:

Biennial

Reporting frequency:

Annual

Penalties:

CARB may impose penalties up to $500,000 in any year for violations

Penalties:

CARB may impose penalties up to $50,000 in any year for violations

Penalties:

CA Attorney General may seek penalties up to $2,500 per day or $500,000 in the aggregate

 

April 2025