
Five years ago, ESG reporting was a voluntary exercise in corporate goodwill. Today, it is a legal requirement for tens of thousands of companies across multiple jurisdictions, with financial penalties, audit requirements, and third-party assurance obligations attached. If your business is not already tracking carbon emissions, 2026 is the year the gap between intention and compliance becomes expensive.
The CSRD is the most comprehensive ESG reporting mandate in force. It replaced the Non-Financial Reporting Directive (NFRD) and dramatically expanded the scope of companies required to report. As of 2026, the directive applies to:
Reports must align with the European Sustainability Reporting Standards (ESRS), which include mandatory climate disclosures covering Scope 1, 2, and 3 greenhouse gas emissions. Third-party limited assurance is required, moving to reasonable assurance by 2028.
The International Sustainability Standards Board (ISSB) issued IFRS S1 (general sustainability disclosures) and IFRS S2 (climate-specific disclosures) in 2023. As of 2026, jurisdictions representing approximately 55% of global GDP have adopted or are in the process of adopting ISSB standards into national law, including the UK, Australia, Canada, Japan, Singapore, and Brazil.
IFRS S2 requires disclosure of climate-related risks and opportunities, governance structures, and GHG emissions (Scope 1, 2, and, where material, Scope 3). It aligns closely with the TCFD framework.
California's Climate Corporate Data Accountability Act (SB 253) requires companies with revenues over $1 billion operating in California to publicly disclose Scope 1 and 2 emissions from 2026 and Scope 3 from 2027. SB 261 requires companies with revenues over $500 million to report on climate-related financial risks. Given California's economic size, these rules function as effective national standards for large US businesses.
The SEC's final climate disclosure rules (adopted March 2024) require domestic US registrants and foreign private issuers to disclose material climate-related risks, governance, and the financial impacts of climate events. Large accelerated filers must include Scope 1 and 2 data with limited assurance; Scope 3 disclosure is required where material or if included in company targets.
Despite their differences, all major ESG reporting frameworks converge on three requirements:
Having advised on ESG disclosure readiness, we see these mistakes repeatedly:
The practical steps for a company beginning its compliance journey in 2026:
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