United States

Sustainibility Disclosure Agreements

Overview

Climate disclosure is no longer optional in the U.S.—from Wall Street to Main Street, regulators are raising the bar. Federal rules and state legislation (especially California) are pushing companies to surface real emissions data and climate risks. Learn how new mandates will shape reporting across sectors.

Who Does This Affect?
  • U.S. public companies (including foreign private issuers)

  • Large partnerships, corporations, and LLCs operating in California

  • Federal contractors with annual contracts >$7.5M

Why Is This Being Introduced?
  • To deliver consistent, comparable, and investor-relevant information on climate risk.

  • To push organizations toward net-zero strategies with measurable disclosures.

What's Required?
  • SEC: Scope 1 & 2 emissions (Scope 3 voluntary), climate-related risk governance, and financial impacts of severe weather or offsets.

  • California SB 253: Scope 1, 2, and 3 disclosures for entities with >$1B revenue doing business in CA.

  • California SB 261: Biennial TCFD-style risk disclosures for companies with >$500M in revenue.

  • Federal Contractors: Tiered emissions disclosures, TCFD-style climate risk assessments, and science-based targets via CDP/SBTi.

  • Fund Naming and ESG Practices: 80% rule for ESG fund investments to prevent greenwashing.

When Is This Happening?
  • SEC: 2026 for FY 2025 disclosures (with phase-ins based on filer type).

  • SB 253/261: Starts in 2026, scaling up assurance through 2030.

  • Contractor rule: Still under review; expected phased rollout one to two years after finalization.

  • ESG Funds: Effective from September 2023.

Where is Reporting Submitted?
  • SEC: Forms 10-K/20-F or amended 10-Qs

  • California: State registry (details pending)

  • Federal Contractors: CDP Climate Questionnaire

  • ESG Funds: Fund prospectuses, Form N-PORT, and Form ADV

Where is Reporting Submitted?

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