Update on United States Climate-Related Disclosure Requirements

On March 27, 2025 the United States Securities and Exchange Commission (SEC) voted to end its defense of the climate disclosure rules adopted on March 6^th, 2024 and stayed shortly after. Investors and stakeholders will now have to depend on state-level climate disclosure laws for assured climate-related information from businesses. Enacted legislation currently exists in California, with Washington, Colorado, New York, New Jersey, Illinois, and Minnesota considering climate disclosure legislation. The table below provides a summary of the expected reporting requirements.

State	Bill	Title	Scope	(Expected) First Report Date	Requires Third-party Assurance
California	SB 219	Greenhouse Gases: Climate Corporate Accountability: Climate-Related Financial Risk	Amends Climate Corporate Data Accountability Act (SB 253) and the Climate-Related Financial Risk Act (SB 261); extends California Air Resources Board's deadline for regulations and allows subsidiaries to consolidate reports. Companies with revenues >$1 billion must disclose GHG emissions Scope 1, 2, 3; companies with revenues >$500 million to disclose climate-related financial risk reports.	2026	(Scope 1 and 2 only)
California	AB 1305	Voluntary Carbon Market Disclosures	Companies that market, purchase, or use voluntary carbon offsets in the state, and make claims regarding the achievement of net zero emissions or other, similar claims are required to detail specific information on the company’s website.	N/A
Washington	SB 6092	Climate Corporate Data Accountability Act	Requires companies with revenues > $1 billion to disclose GHG emissions Scope 1, 2, 3. Similar to California's SB 253.	October 1, 2026 (Scope 1 & 2) October 1, 2027 (Scope 3)
New York	SB S897C	Climate Corporate Data Accountability Act	Requires companies with revenues > $1 billion to disclose GHG emissions Scope 1, 2, 3. Similar to California's SB 253.	2027 (Scope 1 & 2), 2028 (Scope 3)
New York	SB S5437	Climate-Related Financial Risk Disclosure Act	Requires annual climate-related financial risk reports for companies with revenues > $500 million. Similar to California's SB 261.	N/A
New Jersey	SB 4117	Climate Corporate Data Accountability Act	Requires companies with revenues > $1 billion to disclose GHG emissions Scope 1, 2, 3. Similar to California's SB 253.	N/A
Illinois	HB 3673	Climate Corporate Accountability Act	Requires companies with revenues > $1 billion to disclose GHG emissions Scope 1, 2, 3. Similar to California's SB 253.	2027
Minnesota	SF 2744	93^rd Legislature - Climate Risk Disclosure Survey	Requires banks and credit unions with more than $1 billion in assets to make climate risk disclosures by completing a survey by July 30th each year. The survey has not yet been released.	N/A

Most state climate-related legislation emphasizes transparency and accountability for greenhouse gas emissions for companies with revenues exceeding $1 billion USD – with relief extensions for reporting on Scope 3 emissions. Climate-related financial risk disclosure structures are fairly aligned with the IFRS S2 Standard. Specific provisions for emissions registries and public disclosure requirements differ across states.

Colorado’s House Bill 25-1119 was previously on this list of proposed legislation, prior to being indefinitely postponed on February 27^th, 2025. We will continue to track advancements in climate-related disclosure requirements in the United States.