Ceres published an analysis of public comments submitted to the California Air Resources Board on the implementation of California’s 2023 climate disclosure laws, finding that 59% of commenters expressed support and 9% expressed outright opposition. The laws require companies doing business in California to disclose their direct and indirect greenhouse gas emissions and other climate-related financial risk information. The analysis reviewed 245 unique submissions, including 199 institutional letters, and highlighted three recurring themes: calls for interoperability with major disclosure frameworks such as the International Sustainability Standards Board and the EU’s Corporate Sustainability Reporting Directive; requests for clearer criteria for what qualifies as “doing business in California,” including suggestions to use the California Revenue and Tax Code and to add thresholds; and requests for clearer rules on parent-subsidiary reporting and the definition of “revenue” for groups with cross-border structures, with respondents generally supporting consolidated parent-level reporting as satisfying subsidiary compliance. Ceres also submitted its own comment letter summarizing input from more than 100 climate and financial reporting practitioners representing over 70 companies, trade associations, and institutional investors.
Ceres 2025-05-14
Ceres analysis finds 59% of public commenters support California climate disclosure laws
Ceres analyzed public comments on California's 2023 climate disclosure laws, revealing 59% support and 9% opposition. Key themes include calls for interoperability with major disclosure frameworks, clearer criteria for "doing business in California," and rules on parent-subsidiary reporting. Ceres also submitted a comment letter summarizing input from over 100 practitioners across 70 entities.