Insights & Analysis
Evidence-based analysis on US state sustainability regulation and environmental compliance.
California SB 253: What US Companies Need to Know
California’s Climate Corporate Data Accountability Act (SB 253) requires US entities with over $1 billion in annual revenue doing business in California to report Scope 1 and 2 greenhouse gas emissions beginning in 2026. Scope 3 reporting follows in 2027, with CARB proposing an initial focus on five categories.
CARB approved initial implementing regulations in February 2026, establishing applicability definitions, revenue thresholds, and fee assessments. The first reporting deadline has been set for August 10, 2026, though CARB has proposed moving this to November 10, 2026. Critically, SB 253 has not been enjoined — unlike SB 261 (climate-related financial risk), which has been stayed by the Ninth Circuit since November 2025.
Separately, the SEC proposed rescission of its 2024 climate-disclosure rules in May 2026, with the comment period closing in August 2026. Regardless of federal outcomes, California’s requirements and investor expectations ensure that climate-data readiness remains essential for large US companies.
What companies should do now
- Determine applicability — Does your entity exceed $1 billion in annual revenue? Do you “do business in California” under CARB’s definition?
- Establish reporting boundaries — Identify which entities and operations are in scope using GHG Protocol boundary principles.
- Begin Scope 1 and 2 data collection — Activity data for direct emissions and purchased energy should be collected and documented now.
- Prepare for Scope 3 screening — Even though Scope 3 is not due until 2027, a category-level screening should begin early to identify data gaps.
- Build evidence registers — Every data point should be linked to its source document, responsible owner, and review status.
Last reviewed: July 2026
Packaging EPR: Seven States, One Compliance Challenge
Seven US states — California, Colorado, Maine, Maryland, Minnesota, Oregon, and Washington — have enacted comprehensive packaging extended producer responsibility (EPR) laws. The Circular Action Alliance (CAA) serves as the approved Producer Responsibility Organization in most states.
Registration deadlines are already passing. Oregon has been collecting fees since July 2025. Colorado’s programme has been active since January 2026. California’s registration deadline was June 1, 2026. Maryland and Washington deadlines fall in July 2026.
Companies selling packaged goods into multiple states face overlapping obligations with different producer definitions, exemption thresholds, and reporting formats. Mid-market companies are particularly exposed because they may lack dedicated compliance teams but still exceed exemption thresholds in some states.
A coordinated approach
A multi-state compliance strategy is more efficient than addressing each state independently. One data-collection exercise can serve all seven states. One registration process through CAA covers most states. And one compliance calendar can track all deadlines, reducing the risk of missed obligations and duplicate effort.
Last reviewed: July 2026
Illinois CRGA: What Data-Centre Operators Need to Know
Governor Pritzker signed the Clean and Reliable Grid Affordability Act (Public Act 104-0458) on January 8, 2026, with a general effective date of June 1, 2026. The CRGA addresses Illinois’s rapidly growing data-centre sector and its environmental implications.
Beginning December 1, 2026, the CRGA imposes new emission standards on backup generators at data-centre facilities that require a Title V or state operating permit:
- Diesel generators must meet standards at least as protective as EPA Tier 4 (40 CFR Part 1039)
- Natural gas generators must meet standards at least as protective as EPA Tier 2 (40 CFR Part 1048)
Data-centre operators should assess their existing generator fleets, determine whether their facilities trigger permit thresholds, and evaluate the timeline and cost of any required equipment upgrades.
The CRGA also addresses large-load interconnection (ComEd’s pipeline includes approximately 100 projects totalling around 28 GW of potential load), energy storage procurement, and nuclear construction.
Last reviewed: July 2026
From Spreadsheets to Systems of Record
For decades, sustainability teams have relied on spreadsheets to calculate carbon footprints. While flexible, spreadsheets lack the audit trails, access controls, and data lineage required for modern regulatory compliance. In an era of mandatory assurance requirements, a broken formula or a manual data-entry error is no longer a minor mistake — it is a material weakness in your reporting controls.
What is a System of Record?
A System of Record (SoR) for ESG acts as the single source of truth. It automates the ingestion of utility data, production volumes, and spend data, applying validated emissions factors automatically. Key benefits include traceability (every number traces to its original source), audit efficiency (auditors can verify calculations directly in the system), and scenario planning (modelling the impact of operational changes on emissions).
Whether implementing Workiva, Persefoni, FigBytes, or Microsoft Cloud for Sustainability, the goal is the same: treat non-financial data as a strategic asset with the same controls and governance applied to financial data.
Last reviewed: July 2026
Decarbonizing Scope 3: The Supplier Engagement Model
For most sectors, over 80% of emissions lie in the supply chain (Scope 3). Historically, companies have calculated this using spend-based methods — but if you spend more to buy “green” steel, your emissions calculation ironically increases because the spend increased.
The shift to primary data
To show genuine decarbonization, companies must move to hybrid or activity-based models. This requires collecting actual emissions data from suppliers through a structured engagement programme:
- Phase 1 (Education): Hosting webinars to explain to suppliers why you need emissions data and how to provide it.
- Phase 2 (Data Collection): Sending structured surveys to gather Scope 1 and 2 data from critical Tier 1 vendors.
- Phase 3 (Collaboration): Co-investing in efficiency projects with key suppliers to reduce the shared carbon footprint.
Companies that master Scope 3 data don’t just reduce risk; they build resilient supply chains. By identifying carbon hotspots, you often identify energy inefficiencies and cost-saving opportunities deep in your value chain.
Last reviewed: July 2026