BOSTON, May 14, 2025 – An analysis of public comments on the implementation of California’s landmark climate disclosure laws found that 59% of commenters expressed support for the laws, while only 9% expressed outright opposition.
The public comments were submitted to the California Air Resources Board (CARB), which is responsible for implementing the laws. The two laws enacted in 2023 require companies doing business in California to disclose their direct and indirect greenhouse gas emissions and other climate-related financial risk information.
The sustainability nonprofit Ceres analyzed 245 unique submissions to CARB, including 199 institutional letters. Ceres looked at commenters’ perspectives on three key themes that emerged from stakeholder feedback: strong support for global alignment with other disclosure laws, calls for clarity on the definition of companies doing business in California, and clarity on rules that determine which companies report when corporate structures span national boundaries.
Strong Support for Global Alignment: Commenters overwhelmingly recommended that CARB prioritize interoperability with existing reporting frameworks, particularly the International Sustainability Standards Board and the EU's Corporate Sustainability Reporting Directive.
Clarity on the Definition of "Doing Business in California": Many respondents suggested CARB adopt the interpretation found in California Revenue & Tax Code, with others suggesting that CARB adopt additional thresholds to ensure companies have a meaningful nexus to the state.
Clarity on Parent/Subsidiary Relationships and Definition of “Revenue”: Stakeholders requested clear rules for determining how companies with subsidiaries are required to report when corporate structures span national boundaries. There was consensus among respondents that consolidated reporting at the parent level should satisfy compliance for subsidiaries.
"Our analysis found broad support for California's climate disclosure laws, with the majority of investors, companies and other stakeholders advocating for implementation that aligns with global disclosure standards," said Steven Rothstein, Managing Director of the Ceres Accelerator for Sustainable Capital Markets at Ceres. "CARB now has a tremendous opportunity to meet investor and consumer demand for improving corporate climate risk transparency.”
Ceres, which advocated in support of both climate disclosure bills, submitted its own public comment letter in response to CARB’s solicitation, summarizing the views of more than 100 climate and financial reporting practitioners representing over 70 companies, trade associations, and institutional investors.
“Once implemented, these landmark corporate transparency laws will help deliver standardized, high-quality disclosures of companies’ climate-related financial risks to investors and consumers. These bills were passed, signed into law, and subsequently funded with significant company and investor support at every step of the way, and many companies are well prepared to comply with the laws’ provisions,” Ceres wrote.
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About Ceres
Ceres is a nonprofit advocacy organization working to accelerate the transition to a cleaner, more just, and sustainable world. United under a shared vision, our powerful networks of investors and companies are proving sustainability is the bottom line—changing markets and sectors from the inside out. For more information, visit ceres.org.