While simple in structure, these new requirements have complex implications for companies, many of which may not be already gathering and reporting this level of climate data.
The laws were years in the making but have now pre-empted the country-level SEC climate rules that many have been anticipating.
Scope 3 reporting will be required for some companies, which includes the full value chain. Third-party assurance will be required in some cases.
Even though the full extent of the requirements won’t come into force until 2030, the first requirements will be in 2026 covering the year 2025, so companies should get started now.