US disclosure
Climate disclosure software for US climate disclosure requirements
If you have spent a year watching the federal climate rule, the map has changed. On May 29, 2026 the SEC voted to propose rescinding its climate-related disclosure rules in their entirety, and it published that proposal on June 3, 2026 with a comment period that closed August 3, 2026. Those rules had never taken effect: they were adopted in March 2024, then stayed during litigation. A final rescission vote is expected later in 2026. For a US company planning a 2026 or 2027 disclosure, the practical conclusion is that the SEC rule is not the thing to build toward.
What did not go away is state law and the demand coming down your own value chain. California's two climate statutes are on the books, CARB is actively writing the rules, and your customers reporting under CSRD or their own commitments still send you supplier questionnaires. The measurement job is identical whichever of these binds you, which is the whole argument for owning an inventory instead of answering each request from scratch.
| Requirement | Status | Who is affected | What it asks for |
|---|---|---|---|
| SEC climate rule | Proposed for full rescission (May 29, 2026); never took effect | US public companies (if it had survived) | Climate risk, governance, and Scope 1 and 2 for larger filers |
| California SB 253 | In force; CARB rulemaking open; first report November 10, 2026 | US entities over $1B revenue doing business in California | A measured Scope 1 and 2 inventory now, Scope 3 from 2027 |
| California SB 261 | In force; enforcement paused by Ninth Circuit litigation | US entities over $500M revenue doing business in California | A biennial climate-related financial risk narrative |
| Customer and investor requests | Ongoing, contractual | Suppliers to companies that report under CSRD, ISSB or their own targets | Scope 1, 2 and often product- or supplier-level Scope 3 |
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Is the SEC climate disclosure rule still in effect?
No. The SEC adopted climate-related disclosure rules in March 2024 but stayed them almost immediately during litigation, so they never became effective, and on May 29, 2026 the Commission voted to propose rescinding them entirely. The proposal was published June 3, 2026, comments were due August 3, 2026, and a final rescission vote is expected later in 2026. For planning purposes, treat the federal rule as not a live obligation and focus on state law and value-chain demand instead.
What US climate disclosure requirements actually apply in 2026?
One federal obligation does still bite, and it is regularly missed because it predates the disclosure debate entirely. EPA's Greenhouse Gas Reporting Program reaches more than 8,000 US facilities and suppliers, and its reporting year 2025 report is now due March 10, 2027, after EPA extended the October 30, 2026 date in October 2026. EPA has proposed to remove most of it and has not finalized that proposal, so the obligation is live. It is a facility filing rather than a corporate disclosure, and the difference is set out on EPA GHG reporting.
The binding US requirements in 2026 are California SB 253 and SB 261. SB 253 makes US companies over $1 billion in revenue that do business in California report Scope 1 and Scope 2 emissions, with a first deadline of November 10, 2026 and Scope 3 following in 2027. SB 261 makes companies over $500 million publish a biennial climate risk narrative, though its enforcement is currently paused by litigation. Beyond California, many US companies are pulled in indirectly as suppliers to firms reporting under Europe's CSRD.
What does climate disclosure software need to do?
The jobs that survive any regulatory change
- 01 Build the inventory from source data. Scope 1 and 2 come from fuel, refrigerant and utility records; Scope 3 starts from your accounts payable spend. The software should ingest what you already have rather than send you collecting from scratch.
- 02 Classify every line to a GHG Protocol scope and category, with the reason recorded. This is where spreadsheets fail an assurance review, because they cannot tell you why a line was called what it was.
- 03 Keep an evidence trail from every reported figure back to the invoice, meter read or supplier response behind it. Every disclosure regime is a documentation exam before it is a math exam.
- 04 Produce the specific output each request needs, from the same ledger: a CARB submission, a CSRD ESRS E1 pack, a customer questionnaire, an investor answer. Build once, disclose many times.
- 05 Restate cleanly when boundaries and methods change, so last year's number can still be reproduced next year.
That is how our carbon accounting software is built: a classified ledger from the AP and utility data you already own, with line-level evidence attached, so any one of these disclosures is a projection of the same underlying number rather than a separate fire drill. You can run the classifier on your own lines in the demo above before any email address changes hands. If California is your trigger, SB 253 reporting software covers that regime in detail. If your exposure is European, CSRD reporting software and CBAM reporting cover those. If the request came from an investor or a customer rather than a regulator, it is usually a CDP questionnaire, and CDP reporting software covers that cycle and its September 16, 2026 scoring deadline. To compare vendors, see best carbon accounting software.
Which software platforms support California SB 253 and SB 261 compliance, and how do they handle Scope 3?
The two laws need different kinds of software, which is why few platforms cover both well. SB 253 is an emissions inventory: Scope 1 and Scope 2 measured under the GHG Protocol, filed by November 10, 2026, with limited assurance required from the reports submitted in 2027, so it needs carbon accounting software with an evidence trail. SB 261 is a narrative climate risk report in the style of TCFD or IFRS S2, closer to a disclosure document than a calculation. Its enforcement has been paused since the Ninth Circuit granted an injunction pending appeal on November 18, 2025, and no ruling on the appeal had been published when we checked in September 2026, so SB 261 reporting is voluntary for now.
On Scope 3, the first SB 253 report has none. Scope 3 is due from 2027, and CARB has previewed but not adopted the categories and method rules, so a platform that tells you exactly what Scope 3 will require is ahead of the regulator. What a platform can do now is build Scope 3 from your accounts payable so the 2027 number has a tested base year behind it.
| Platform | SB 253 | SB 261 | Scope 3 |
|---|---|---|---|
| CarbonAccounting.ai | Scope 1 and 2 inventory with line-level evidence; Compliance plan $1,290 a month | Supplies the emissions metrics; we do not write the risk narrative | Classified from the AP ledger into the 15 categories, ready for 2027 |
| Persefoni | Managed SB 253 service, quoted (listed from $25,000 until October 2026) | Managed SB 261 report, quoted (listed from $25,000; both $40,000) | Platform covers Scope 1 to 3 |
| Watershed | Guaranteed Assurance offer, fees waived up to $250,000 if assurance fails, with conditions | Climate risk assessment and SB 261 disclosure in the same platform, per its California page | Platform covers Scope 1 to 3 plus supplier programs |
| Hydrus | Listed framework; SB 253 readiness sold as consulting | Listed framework | Spend-based, average-data, supplier-specific and hybrid methods |
The full SB 253 checklist is on SB 253 reporting software, and the vendor detail behind this table is on Persefoni alternatives, Watershed alternatives and Hydrus AI alternatives.
Does the SEC rescission mean I can stop measuring emissions?
No, and treating it that way is the expensive mistake. The federal rule going away does not touch California SB 253, it does not touch your customers' supplier questionnaires, and it does not touch CSRD obligations that reach US firms through the value chain. A company over $1 billion in revenue with California business still has a November 10, 2026 deadline. The demand for a defensible emissions number now comes from states, customers and investors rather than one federal rule, and those sources are not going to coordinate a pause.
Climate disclosure FAQ
01 Is the SEC climate disclosure rule still in effect?
02 What US climate disclosure requirements actually apply in 2026?
03 Does the SEC rescission mean I can stop measuring emissions?
Regulatory facts here describe US federal and California climate disclosure rules as published in July 2026, including the SEC's proposed rescission and the open CARB rulemaking; dates and requirements can change, so confirm current status with the SEC and CARB. Nothing here is legal advice.
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