Companies can’t wait for specifics on the state’s climate rules. Here's four moves to make now.

California’s disclosure laws are a catalyst. And the clock is ticking

  • 4 minute read
  • August 27, 2025

California’s climate laws represent a defining moment for many companies. With the passage of SB 253 and SB 261, as modified by SB 219, many companies are facing their first regulatory climate disclosure mandates in the US. These laws apply to both public and private companies and require disclosure of greenhouse gas emissions and climate-related financial risks. 

The California Air Resources Board (CARB) — the agency tasked with responsibility for rulemaking development, implementation and enforcement — is moving to transform voluntary disclosure frameworks into regulatory grade standards. Companies in scope of the state’s laws will need to disclose a climate-related financial risk report by January 1, 2026 and scope 1 and scope 2 emissions in 2026, with independent third-party limited assurance. Scope 3 emissions reporting begins in 2027.

The central challenge? While companies know what they will need to disclose, they still do not know key details. These laws describe preparing disclosures in accordance with the Greenhouse Gas Protocol and the Task Force on Climate-Related Financial Disclosures’ 2017 Guidance and the International Sustainability Standards Board’s S2 Climate-Related Disclosures. But CARB is still discussing how to define key terms such as “revenue” and “doing business in California,” which may impact which companies are in scope. 

As companies also prepare for compliance with other global regulations like the Corporate Sustainability Reporting Directive (CSRD), California’s timeline leads to a predicament: Organizations risk being caught flat-footed if they wait for every detail to crystalize.

Reporting Your next climate reporting moves

Companies should evaluate and formalize their processes and build systems and capabilities that give them flexibility for whatever the details of compliance look like. That includes identifying where practices fall short, pressure-testing processes, taking climate risk assessments through internal audit review and designing reporting programs that are interoperable and support a single source of data that can be used to satisfy multiple disclosure requirements. 

Wherever companies are on their sustainability journeys, these four no-regrets moves can help them navigate uncertainty and build climate reporting that’s ready for California and beyond.

A gap assessment can compare current practices on climate risk and strategy to California’s requirements. AI can accelerate a company’s ability to quickly execute a gap assessment by analyzing the relevant content and data, identifying and analyzing gaps, making recommendations on how to fill them and then generating compliance-ready reports.  This process may also highlight inconsistencies in governance documentation or risk management and can help leadership allocate resources effectively between quick wins (like improving governance narratives) and long-term needs (like building climate data infrastructure). 

SB 261 calls for disclosure of climate-related financial risks, including physical and transition risks. Companies may be able to disclose the results of qualitative processes to evaluate risk if they have not completed quantitative analysis, such as scenario modeling. The climate risk analysis process will reveal key insights on risks, costs of inaction, and pathways to greater resilience acknowledging that yesterday’s assumptions can no longer guide tomorrow’s decisions. Companies may also want to consider the consistency of identified risks with other disclosures such as their current SEC reporting and CDP responses.

Under SB 253 reporting GHG emissions data is not optional. Companies that begin now will not only be better prepared to meet disclosure obligations but will also strengthen trust and credibility with stakeholders. Compiling a thorough emissions inventory can help measure emissions, anticipate climate risks, and enable target setting, allowing your organization to model the impact of decarbonization initiatives.

As written in the law, companies will need to have processes that align with the Greenhouse Gas Protocol. AI can help. Think about your investment in auditable GHG data as a down payment on trusted content for AI-driven workflows that can help you decarbonize operations and lower your business risk.

California requires independent third-party assurance over a company’s emissions reporting, starting with limited assurance and moving to reasonable assurance in subsequent periods. To make that shift, companies should evaluate their existing controls for other mandatory or voluntary reporting and determine if they are adequate for addressing the state’s regulatory requirements. Focus on scope 1 and scope 2 emissions and climate-related risks, applying foundational steps including but not limited to clear roles, documentation standards and validation processes. Strong internal controls enable the business to use greenhouse gas information like carbon-exposed margin insights in key decisions and disclosure. PwC is working with companies to combine AI and trusted test scripts to improve controls without increasing headcount.

Reporting California may be the first test. It won’t be the last.

The reporting challenges companies face today are only the beginning. In the absence of a federal standard, other states may follow California’s lead and try to enact their own climate-related disclosure laws increasing the risk of patchwork regulation. 

But the real shift is this: companies will be pushed to disclose, and to do so with higher-quality, decision-useful information that investors are demanding. California’s rules set the tone for a broader wave of transparency, one that could reshape how markets evaluate risk and resilience.

Don’t look at California’s legislation as just another compliance exercise. It’s the spark to build repeatable, auditable, interoperable sustainability reporting capabilities, ones that can make your business faster, smarter and more resilient

Contact us

Kevin O’Connell

Kevin O’Connell

Sustainability Assurance Services Leader, PwC US

Brigham McNaughton

Brigham McNaughton

Sustainability Partner, PwC US

Ariane Burwell

Ariane Burwell

Director, Sustainability, PwC US

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