Before building a reporting timetable, confirm the jurisdiction, entity scope, reporting period, and current legal status. Keep the source and review date beside each requirement. The summaries below are orientation only; qualified counsel should confirm applicability and current obligations.
California: distinguish the two programs
California Air Resources Board (CARB) announced approval of its initial regulation in February 2026, including an August 10, 2026 first-year Scope 1 and 2 reporting deadline under Senate Bill 253. Its announcement states that Senate Bill 261 is not being enforced pursuant to a court order and reporting is voluntary.
That deadline is now past. Check current CARB guidance and litigation developments before relying on the announcement for a present filing decision. The statutes, as amended by Senate Bill 219, should not be treated as having identical implementation status.
United States: a rescission proposal is not a final repeal
The Securities and Exchange Commission proposed rescinding its climate-disclosure rules on May 29, 2026. Its release describes the existing stay and the litigation’s abeyance. The reviewed source is a proposal; it does not establish a completed repeal or remove other potentially applicable disclosure obligations.
European Union: reassess scope and timing
The Council announced final approval of the Omnibus I simplification in February 2026. Its summary raises the Corporate Sustainability Reporting Directive’s general thresholds to more than 1,000 employees and above €450 million net annual turnover, with separate provisions for third-country groups and transition exemptions. Check the enacted text, national implementation, and applicable European Sustainability Reporting Standards before reaching an entity-specific conclusion.
The European Commission adopted revised European Sustainability Reporting Standards on July 3, 2026, subject to Parliament and Council scrutiny. The Commission’s implementing-acts register identifies the July 3 delegated regulation as not in force until publication in the Official Journal. Confirm that register and the final application provisions when selecting the reporting basis.
Singapore: use the right company tier
The Accounting and Corporate Regulatory Authority’s July 2026 roadmap distinguishes listed-company tiers and large non-listed companies. It phases climate reporting, Scope 3 reporting, and assurance separately. Draft local disclosure standards were put out for consultation in July 2026; a consultation should not be described as a final standard.
Philippines: adoption is being phased in
The IFRS Foundation’s July 2026 jurisdictional profile confirms Philippine Securities and Exchange Commission Memorandum Circular No. 16, series of 2025, introduces Philippine Financial Reporting Standards S1 and S2 with phased adoption beginning in fiscal 2026. Confirm the entity’s tier, transition reliefs, and submission requirements against the circular and subsequent regulator guidance.
Keep a useful management register
Record the business trigger, source, legal status, legal-review owner, reporting period, evidence owner, and next review date. Separate legal requirements from customer or lender requests, which may still require a response even when statutory reporting is deferred.
Review note: Linked primary-source publications rechecked September 17, 2026. These summaries describe the cited publications, not a comprehensive litigation or applicability review. Regulatory changes may occur after the cited publications. This article does not determine legal applicability or provide legal advice.
Sources and further reading
- Directive (EU) 2026/470, enacted text
- European Commission: CSRD implementing and delegated acts
- European Commission: revised ESRS, July 3, 2026
- IFRS Foundation: Philippines profile, July 10, 2026 (PDF)
- CARB: initial climate transparency regulation
- U.S. SEC: proposed rescission, May 29, 2026
- Council of the EU: Omnibus I approval, February 24, 2026
- ACRA: reporting and assurance roadmap
- ACRA: July 2026 draft standards consultation