The global ESG and sustainability reporting focus is shifting from being largely voluntary to a mandatory disclosure landscape. Underpinning this shift is a patchwork of global regulations with various environmental, social and governance (ESG) disclosure requirements. The jurisdiction, scope, and timeline for these regulations are incredibly dynamic challenging U.S. companies to determine the applicability and requirements.
This article discusses the most impactful mandatory ESG and sustainability reporting regulations, which redefines the need for organizations to formalize their ESG reporting capabilities. This includes:
- California Climate Accountability Package: SB 253 California Climate Corporate Data Accountability Act
- California Climate Accountability Package: SB 261 Greenhouse Gasses: Climate-Related Risk
- California Voluntary Carbon Market Disclosure Rule: AB-1305 Voluntary Carbon Market Disclosures
- New York Climate Corporate Accountability Act
- New Jersey Climate Corporate Accountability Act
- Illinois Climate Corporate Accountability Act
- Corporate Sustainability Reporting Directive (CSRD)
Organizations should determine which ESG and sustainability regulations apply to them and prepare now to protect against risks associated with inaction. Download the easy-to-follow checklist of regulatory applicability to understand if your organization is impacted.

With a growing patchwork of state-led climate-related regulations emerging across the U.S., companies must prepare for compliance. California’s landmark Climate Accountability Package is setting a precedent, requiring detailed emissions disclosures from large companies operating in the state. Other states — including New York, New Jersey and Illinois — are following suit with their own climate transparency proposals. Even if your company isn’t directly subject to these laws, you may still need to furnish climate data to regulated suppliers or align reporting across multiple jurisdictions. Proactive engagement now allows companies to build scalable systems and controls that are cost-effective, operationally feasible and strategically advantageous. And with international frameworks like the European Union (EU) CSRD raising the bar globally, harmonizing your approach is no longer optional — it’s essential.
Get ahead of the changing regulatory landscape by acting today to understand how your organization could be impacted in the future. Lean on our specialists to guide the way and act now to protect and enhance your organization’s value.
1. California Climate Accountability Package: SB 253 California Climate Corporate Data Accountability Act
For the latest information, please reference this article: California’s climate disclosure regulations: An update on SB 253 and SB 261.
2. California Climate Accountability Package: SB 261 Greenhouse Gasses: Climate-Related Risk
For the latest information, please reference this article: California’s climate disclosure regulations: An update on SB 253 and SB 261.
3. California Voluntary Carbon Market Disclosure Rule: AB-1305 Voluntary Carbon Market Disclosures
Released alongside the California Climate Accountability Package in October 2023, the California Voluntary Carbon Market Disclosure Rule, also known as Assembly Bill 1305 (AB-1305), seeks to bring transparency to the voluntary carbon market by requiring specific annual disclosures for organizations who make carbon reduction claims, market or sell carbon credits, or purchase carbon credits.
- Businesses making claims about net zero, carbon neutrality, or significant GHG reductions in California who purchase or use voluntary carbon offsets
- Companies that market or sell voluntary carbon offsets in California
The concept of materiality is not incorporated into this bill. Companies are required to disclose if they make carbon reduction claims, market or sell carbon credits, or purchase carbon credits.
The bill went into effect January 1, 2024, however, there is uncertainty regarding disclosure reporting effective dates.
- For companies that make carbon reduction claims regarding the achievement of net zero emissions through the purchase of carbon credits, (i.e., net zero, carbon neutrality) in the state, the bill requires disclosure regarding details of the carbon offset project(s), how the claim is determined to be accurate, and how progress against the claim is measured. Additionally, the bill requires disclosure of whether the data has received assurance by a third party. Disclosures are required on an annual basis and must be made publicly available.
- For companies that market or sell carbon credits in the state, the bill requires disclosures regarding details of the carbon offset project and the amount of emissions reduced or carbon removed. Disclosures are required on an annual basis and must be made publicly available.
4. New York Climate Corporate Accountability Act
The Climate Corporate Accountability Act, introduced in February 2023, is a proposed amendment to the environmental conservation law which would require New York companies to report on and obtain assurance (ESG data audit) over their full GHG inventories, which include scope 1, 2 and 3. The act would require annual GHG emissions reporting to the state’s GHG emissions registry.
Companies with $1B+ in revenue who do business in the state of New York. The following activities constitute doing business in the state of New York:
- operating a branch in New York State
- operating a loan production office in New York State
- operating a representative office in New York State or
- operating a bona fide office in New York State
Single (financial materiality)
The phased timeline for implementation for scope 1 and 2 starting in 2027 and scope 3 starting in 2028.
Companies will be required to annually and publicly report scope 1, 2 and 3 GHG emissions data.
5. New Jersey Climate Corporate Accountability Act
On March 17, 2025, the New Jersey bill (S4117) was referred to the Senate Budget and Appropriations Committee. It mandates entities with over $1 billion in annual revenue that do business in New Jersey to publicly report on their full greenhouse gas (GHG) inventories, which include scope 1, 2 and 3.
Entities with $1B+ in revenue who do business in the state of New Jersey. Generally, “doing business” is defined as regularly engaging in transactions for financial gain, having employees or property located within the state of New Jersey. Partnerships, corporations, limited liability companies and other business entities formed in the United States that do business in New Jersey with total annual revenues in excess of $1 billion would have reporting requirements under this bill.
Single (financial materiality)
Disclosure timeline has not been determined yet at this time.
Companies will be required to annually and publicly report scope 1, 2 and 3 GHG emissions data.
6. Illinois Climate Corporate Accountability Act
The Illinois Climate Corporate Accountability Act (HB4268) is a recently enacted law in Illinois that mandates entities with over $1 billion in annual revenue that do business in Illinois to publicly report on their full greenhouse gas (GHG) inventories, which include scope 1, 2 and 3.
Entities with $1B+ in revenue who do business in the state of Illinois. Generally, “doing business” is defined as regularly engaging in transactions for financial gain, having employees or property located within the state of Illinois. Partnerships, corporations, limited liability companies and other business entities formed in the United States that do business in Illinois with total annual revenues in excess of$1 billion would have reporting requirements under the Illinois Climate Corporate Accountability Act.
Single (financial materiality)
Phased implementation starting January 1, 2027.
Companies will be required to annually and publicly report scope 1, 2 and 3 GHG emissions data.
7. Corporate Sustainability Reporting Directive (CSRD)
The CSRD went into effect in the European Union (EU) in January 2023 requiring companies to report on the impact of corporate activities on the environment and society, while requiring disclosures on various governance topics. To ensure accuracy of the data reported, the CSRD requires assurance (ESG data audit) of reported information. The CSRD amends and builds on the Non-Financial Reporting Directive (NFRD) which required disclosure regarding ESG topics. The enhanced regulation will require disclosures according to the European Sustainability Reporting Standards (ESRS). The first set of ESRS were finalized in July 2023 with sector-specific standards expected in June 2024. The disclosure requirements of the CSRD are comprehensive and may differ depending on applicability.
- U.S. companies that are considered “large EU company” or “large group” including those listed on EU-regulated markets and not listed as well as U.S. parent company subsidiaries located in the EU and non-EU companies generating a net turnover of €150 million in the EU.
- Organizations are considered a “large EU company” including EU based subsidiaries of non-EU parent companies if they meet two of the three criteria: average number of employees during the fiscal year is 250 employees, total assets are more than €25 million and net turnover more than €50 million.
- Non-EU companies generating a net turnover of €150 million in the EU and have:
- A subsidiary in the EU that meets the forementioned criteria or
- A branch in the EU generating a net turnover more than €40 million
Double (financial and impact materiality)
The CSRD is currently in effect. Large companies who are currently subject to the NFRD are required to provide disclosures starting in 2025 for fiscal year 2024. Large EU companies not currently subject to the NFRD will report in 2026 for fiscal year 2025. Non-EU companies that meet criteria will be required to publish a 2028 report in 2029.
Disclosure of five main dimensions from NFRD [1] (precursor), and disclosure of general, environmental, social and governance topics [2]. Additionally, the report must be in a standardized, electronic and searchable reporting format.
Footnotes
[1] The five main dimensions from the NFRD, a precursor to the CSRD include disclosures regarding environmental protection, social responsibility and workforce treatment, respect for human rights, anti-corruption and bribery, and diversity of boards. The CSRD goes further than the NFRD and expands on the sustainability reporting standards of the NFRD.
[2] General disclosures include double materiality, business model and strategy, climate transition plans, time-bounded targets, sustainability due diligence, information on own operations, value chain, business relationships and supply chain. Specific to the supply chain, documentation of adverse impacts and actions to prevent/mitigate risk is required. Environmental disclosures include disclosures covering each of the EU Taxonomy environmental objectives which are climate change mitigation (incudes scope 1, 2 and 3 GHG emissions), climate change adaptation, water and marine resources, biodiversity, and eco system, resource use and circular economy. Social disclosures include disclosures regarding diversity and inclusion, human rights, working conditions, health and safety, employee relations, pay gaps, related rights, workers in the value chain, affected communities, consumers and end-users. Governance disclosures include disclosures regarding policies, risk management and internal controls, ownership and structural transparency, independence and oversight, responsible business practices, ethics, anti-corruption and executive pay fairness.
[3] Significant contractors are those that received between $7.5 million and $50 million in federal contract obligations in the prior federal fiscal year.
[4] Major contractors are those contractors that received more than $50 million in federal contract obligations in the prior federal fiscal year.
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