The United States climate-disclosure landscape moved in two directions in 2026. The Securities and Exchange Commission proposed rescinding its 2024 federal climate rules, while California continued implementing corporate greenhouse gas and climate-risk reporting requirements.
US companies therefore need a jurisdiction map, not a single yes-or-no answer about climate reporting.
The SEC has proposed a full rescission
On May 29, 2026, the SEC proposed rescinding its climate-related disclosure rules in their entirety. The agency had already voted in March 2025 to end its defense of the rules in ongoing litigation.
A proposal is not a final rule. Reporting teams should monitor the SEC proceeding and current filing requirements, but should not continue a large implementation program solely on the assumption that the 2024 rule will take effect as written.
That does not remove ordinary federal disclosure duties. Public companies still need processes for identifying information that is material under existing securities law, including material risks that relate to climate. Legal counsel should determine how those duties apply to a company’s facts and filings.
California reporting continues on a separate track
California’s Climate Corporate Data Accountability Act, SB 253, applies to US-based entities doing business in California with more than $1 billion in annual revenue. Scope 1 and Scope 2 reporting begins in 2026; Scope 3 follows in 2027. CARB approved an initial implementing regulation in February 2026.
The Climate-Related Financial Risk Act, SB 261, generally applies at a lower revenue threshold of more than $500 million for covered US-based entities doing business in California. It requires biennial public reporting on climate-related financial risk and measures adopted to reduce and adapt to that risk.
The statutes have different thresholds, deliverables, and control needs. A company may fall under both, one, or neither. It should preserve a written applicability assessment for each law rather than using the SB 253 conclusion as a proxy for SB 261.
Companies completing their first emissions submission can use our California SB 253 deadline checklist to review boundaries, periods, calculations, and filing evidence.
Other requirements can still create a reporting obligation
The SEC proposal does not override state law, contractual obligations, lender requests, customer questionnaires, or foreign reporting requirements. A US parent can also become part of an overseas group disclosure through subsidiaries, listings, financing arrangements, or value-chain relationships.
Create a reporting-requirement register with one row per obligation. At minimum, record:
- The legal entity and jurisdiction.
- The rule, contract, or voluntary commitment.
- The applicability threshold and evidence supporting the conclusion.
- The reporting period, filing date, and publication channel.
- Required metrics, narrative, assurance, and executive approvals.
- The owner responsible for monitoring rule changes.
This prevents a federal policy change from accidentally stopping work that remains necessary for California or another stakeholder.
Build one inventory that can serve multiple regimes
A reporting team should avoid creating a separate GHG calculation for every request. Build a controlled corporate inventory first, then transform it into each required output.
The foundation includes a documented organizational boundary, a complete source population, controlled unit conversions, versioned emission factors, estimation rules, variance reviews, and an audit trail from disclosed totals back to source evidence.
For Scope 2, preserve both calculation paths where dual reporting applies. For Scope 3, screen all categories, record exclusions and methods, and prioritize data improvements using the distinction among spend, activity, and supplier-specific data.
A practical response to regulatory uncertainty
Classify planned work into three groups:
- Required now: activities tied to an enacted, applicable requirement or existing material-disclosure duty.
- No-regret infrastructure: inventory controls, ownership, evidence, and governance that support several reporting outcomes.
- Rule-specific work on hold: templates or controls useful only if a proposal becomes final in a particular form.
This approach preserves readiness without treating every proposal as settled law. It also gives executives a clearer explanation of which costs are mandatory, reusable, or contingent.
Information in this article was verified on August 9, 2026. Federal and state proceedings may change, and applicability is fact-specific. This overview is general information, not legal advice.
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