Davis Polk counsel David Zilberberg discussed California’s climate disclosure requirements and the impact that the current implementation deadlines may have on companies with the Wall Street Journal.

“Late last year when these laws came out, we were just bombarded with calls from clients asking, ‘what should we be doing?’” David said.

The article notes that as the law is written, companies would need to collect Scope 1 and 2 emissions data for fiscal year 2025 to meet the 2026 reporting deadline. Scope 3 reporting requirements would roll out in 2027. A recent proposal by California Governor Gavin Newsom to push back the requirements by two years was rejected by state legislators.

“Companies would have to be really far along in their internal organizing to make sure that they’re in a position to comply,” David explained.

“California Legislature Rejects Delay to Emissions-Reporting Rules,” Wall Street Journal (September 4, 2024) (subscription required)

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