An emissions spreadsheet arrives with a customer’s purchasing request. A lender sends a questionnaire before a credit review. Meanwhile, a colleague asks whether a climate disclosure rule covers the business. The first decision is whether these questions belong in the same work plan.
Our view is that they should share evidence, but each needs its own answer about scope, recipient and timing. Starting with a generic sustainability report can leave you with extensive narrative and no response to the number the buyer needs. Starting with each questionnaire independently can create conflicting versions of that number.
Separate a legal duty from a commercial request
As of November 12, 2026, CARB’s program page describes SB 253 reporting entities as businesses formed under the laws of California, any other U.S. state, the District of Columbia, or an act of Congress, with annual revenue above $1 billion, that do business in California. Its October 12 notice states that the initial regulation took effect that day and sets November 10, 2026 as the first reporting deadline. [1, 2] Whether your company is covered is a separate question.
For a coverage review, assemble the entity’s formation documents, group structure, revenue information and California activity. Ask counsel to assess the applicable definitions. Record the legal entity covered by the conclusion.
As of this article’s November 12, 2026 review, the Ninth Circuit’s November 9 opinion affirms the denial of preliminary relief for SB 253 Scope 1 and 2 disclosures. It reverses the denial as to Scope 3 and SB 261 and remands for the district court to decide whether the Scope 3 provisions are severable. [3, conclusion] Do not describe that preliminary decision as the final resolution of every challenge to California’s laws.
The practical recommendation is to track the law, implementing regulation and court developments separately. If the first deadline may have applied and the business has not acted, seek advice promptly about its position and next steps. Do not infer an extension from the existence of litigation or from a customer’s different deadline.
A stalled federal rule does not answer the customer
As of November 12, 2026, the SEC source reviewed for this article is its May 29 proposed rescission. That release describes the 2024 climate rules as stayed and proposes to withdraw them. It is a proposal, not a final withdrawal. [4] Check the current docket before making a filing decision.
Our view is that the immediate management question is narrower: which request is actually waiting for an answer? A procurement request does not disappear because a federal rule is stayed. Equally, a voluntary questionnaire should not be presented internally as a statutory filing merely because it asks about the same emissions.
CDP provides a concrete example of separate request channels. Its disclosure page says companies can be requested by capital market signatories or supply chain members, and can also disclose voluntarily. Responses use its questionnaire. [5] The requester, not the topic, determines what is being asked.
Ask the person forwarding a request to retain the original instructions, not just the spreadsheet. The accompanying message may settle the period covered, submission route, access permissions or due date. Where it does not, ask the requester for a written answer before the team starts making assumptions.
Build one evidence file and several purposeful responses
Exhibit: The same data needs a different decision owner for each request.
| Request route | Establish first | Our suggested response owner |
|---|---|---|
| California reporting review | Covered entity, applicable rule and current court position [1–3] | Legal and finance |
| Investor information | Industry metrics and the investment question [6] | Finance and investor relations |
| Lender questionnaire | Exact credit-review or contractual request | Treasury or the financing lead |
| Customer questionnaire | Supplier, site or product boundary and requested period | Account lead and operations |
SASB Standards offer industry-based information about sustainability risks and opportunities relevant to investors. The IFRS Foundation describes their focus in terms of cash flows, access to finance and cost of capital. [6] Use that purpose to discuss the investor’s question; do not assume that naming SASB completes the response.
For a lender request, our recommendation is to distinguish evidence about current operations from forecasts, targets and management plans. Ask whether the lender wants a group inventory, site information, exposure to physical hazards or another defined input. Confirm whether a question is contractual, part of due diligence or optional. Avoid promising that a completed questionnaire will improve loan pricing or secure credit.
For a customer request, ask which entity, facility or product the answer should describe. If the requested information is broader than the evidence available, explain the boundary and limitation before submission. Keep the commercial account lead involved so that technical uncertainty is not silently converted into a contractual assurance.
Start with the next decision, then make the process reusable
Our suggested first deliverable is a request register. Give every request an owner, recipient, deadline, stated authority and reporting boundary. Add the evidence source for each repeated metric. A request becomes easier to manage when someone can say what decision is blocked and what information would resolve it.
Next, identify overlaps without erasing differences. A reviewed energy record may support several calculations. A corporate total should not simply be pasted into a product question. Keep each submitted answer, its supporting calculation and its review date together. If a figure changes, make the reason visible to the people preparing other responses.
Use a short internal review before sending anything. Ask whether the response answers the actual question, whether its period is clear, and whether its qualifications survive being copied out of the file. Check that estimates are identified and that an aspiration has not become a statement about achieved performance.
For the next request on your desk:
- Identify the requester, decision, deadline and legal or commercial basis.
- Confirm the entity, site or product boundary before collecting figures.
- Reuse reviewed evidence with its original assumptions and limitations attached.
- Obtain the appropriate internal review and retain the submitted version.
Related service: ESG reporting. Talk to us.
As of November 12, 2026. The law and the court position can change; check the current position before you rely on this. General information, not legal advice.
Sources
[1] California Air Resources Board, California Corporate Greenhouse Gas Reporting and Climate Related Financial Risk Disclosure Programs, undated program page. Retrieved November 11, 2026. Program.
[2] CARB, Notice of Office of Administrative Law Approval, October 12, 2026. Retrieved November 11, 2026. Notice.
[3] U.S. Court of Appeals for the Ninth Circuit, United States of America Chamber of Commerce v. Sanchez, No. 25-5327, November 9, 2026, majority conclusion. Retrieved November 11, 2026. Opinion.
[4] U.S. Securities and Exchange Commission, Rescission of Climate-Related Disclosure Rules, Release 33-11421, May 29, 2026, proposed withdrawal, introduction and section II. Retrieved November 11, 2026 through the web renderer. Release.
[5] CDP, Disclose Data, undated. Retrieved November 11, 2026. Disclosure routes.
[6] IFRS Foundation, SASB Standards, undated. Retrieved November 11, 2026. Standards.
