Ceres published an analysis of public comments submitted to the California Air Resources Board (CARB) on implementing California’s 2023 climate disclosure laws, finding that 59% of commenters supported the laws and 9% expressed outright opposition. The laws require companies doing business in California to disclose direct and indirect greenhouse gas emissions and other climate-related financial risk information. The review covered 245 unique submissions, including 199 institutional letters, and highlighted three recurring themes in stakeholder feedback. Commenters urged CARB to prioritise interoperability with existing disclosure frameworks, particularly the International Sustainability Standards Board and the European Union’s Corporate Sustainability Reporting Directive. They also called for clearer criteria for what qualifies as “doing business in California”, with many recommending use of the California Revenue and Tax Code interpretation and others proposing additional nexus thresholds. A third focus was on parent-subsidiary reporting and the definition of “revenue” for groups with cross-border corporate structures, with respondents generally aligning around consolidated parent-level reporting as sufficient to cover subsidiaries.
Ceres 2025-05-14
United States' Ceres analysis finds 59% support for California climate disclosure laws in CARB implementation comments
Ceres analyzed public comments on California's 2023 climate disclosure laws, revealing 59% support and 9% opposition. Key feedback urged CARB to align with existing frameworks like the International Sustainability Standards Board and the EU's Corporate Sustainability Reporting Directive, clarify criteria for "doing business in California," and adopt consolidated parent-level reporting for cross-border corporate structures.