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#DeloitteESGNow — The Sweeping Impacts of California’s Climate Legislation (October 10, 2023)

Heads Up | Volume 30, Issue 18
October 10, 2023
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#DeloitteESGNow — The Sweeping Impacts of California’s Climate Legislation


Both bills apply to U.S.-based companies but use slightly different terminology. SB-253 defines a “reporting entity” as “a partnership, corporation, limited liability company, or other business entity formed under the laws of this state, the laws of any other state of the United States or the District of Columbia, or under an act of the Congress of the United States.” SB-261 defines a “covered entity” similarly; however, it excludes companies in the insurance business.
Floor analyses of SB-253 and SB-261.
The GHG Protocol was developed and updated by the World Resources Institute and the World Business Council for Sustainable Development.
Starting in 2030, entities may need to disclose Scope 3 GHG emissions “as close as practicable” to their disclosure timing for Scope 1 and Scope 2 GHG emissions; however, the California Air Resources Board will evaluate this in 2029 on the basis of current trends in Scope 3 GHG emission reporting.
Scope 3 assurance requirements to be determined by 2027.
Companies may also report in accordance with an “equivalent reporting requirement” (e.g., IFRS Sustainability Disclosure Standards, issued by the ISSB).
In April 2022, the National Association of Insurance Commissioners in conjunction with the internationally recognized TCFD adopted a new standard for insurance companies’ reporting of their climate-related risks.
Reporting date to be determined by CARB.
The table provides a high-level comparison of certain metrics and requirements in different climate disclosure regulations. However, because of its condensed format, the table does not take into account all scope or disclosure scenarios. See the Other Resources section for additional information about other existing or proposed climate disclosure regulations.
The SEC climate rule has been proposed but not yet finalized; all specifications in the table are based on the proposed regulation and are subject to change.
Proposed SEC implementation timeline would require initial reporting in 2024 for a large accelerated filer; however, the timeline reflected in the SEC proposal is likely to differ from the timeline in a final SEC rule.
IFRS S1, General Requirements for Disclosure of Sustainability-Related Financial Information, and IFRS S2, Climate-Related Disclosures.
The CSRD requires assessment of materiality from both an impact and a financial perspective (a concept known as “double materiality”).
“An entity need not disclose information otherwise required by an IFRS Sustainability Disclosure Standard if the information is not material” on the basis of an assessment of materiality as defined in IFRS S1.
See footnote 17.
See footnote 14.
See footnote 15.