2024 is a crucial year for climate reporting. Under new mandates, many companies will have to share details about their carbon emissions and climate targets starting now. Whether you’re subject to regulated disclosure, or reporting voluntarily, in 2024, you'll need to be ready to meet a new high bar for carbon accounting.
In this article, we’ll break down the different frameworks and regulations businesses need to pay attention to in 2024, along with key reporting timelines and requirements.
The Current State of Climate Reporting
The disclosure standards, frameworks, and regulations that companies are subject to vary widely from entity to entity — and will shape your planning in 2024. The jurisdiction you operate in, your company’s size, and stakeholder expectations will all influence which standards and timelines you must adhere to.
Below, we provide an overview of what reporting timelines might look like for different companies. To be clear, this is a snapshot and is not meant to provide a determination of how your company should be reporting. We recommend you work with your legal team to review and assess your specific reporting requirements.
Mandatory Reporting
We are seeing a rapid evolution from an atmosphere dominated by voluntary reporting, to a regulated one. Businesses must now navigate emerging mandates from state, federal, and global jurisdictions. In 2024, companies need to pay attention to several key regulations and reporting deadlines, including (but not limited to):
California SB 253
The Climate Corporate Data Accountability Act, SB 253, is a new law requiring businesses with revenues greater than $1B USD that operate in California to report their greenhouse gas emissions publicly.
Companies will need to disclose scope 1 and 2 emissions with limited assurance in 2026, using data from FY2025. There is a one-year phase-in period for scope 3 reporting, meaning companies will need to report on scopes 1, 2, and 3 in 2027 using FY2026 data. Because the implementing regulations have not been issued, lawmakers have not yet defined exactly when in the year the deadline will be set.
SEC Climate Disclosure Rule
The SEC Climate Disclosure Rule, affecting U.S. Public Companies and Foreign Private Issuers, aims to meet investor demands for consistent climate-related disclosures. It requires narrative disclosures on climate-related risks, disclosure of material scopes 1 and 2 emissions by certain filers, and financial statement disclosures of severe weather impacts and carbon offset use.
The rule will be phased in, with the first disclosures due in 2026 for FY 2025 reporting, and reporting required in Forms 10-K or Form 20-F, and registration statements, with flexibility for gathering emissions data in Q2 filings if needed.
Corporate Sustainability Reporting Directive (CSRD)
The CSRD will require disclosure from large EU-based public and private entities, including organizations with subsidiaries in Europe. The regulation will phase in over four years, expanding to nearly 50,000 companies by 2028. For large, listed Public Interest Entities (“PIEs”), reporting begins in FY2024. Small and medium enterprises listed on EU exchanges will come into scope in FY2026. In FY2028, reporting will include companies with branches or subsidiaries in Europe, with specific revenue thresholds for global parent reporting.
SECR
Streamlined Energy and Carbon Reporting (SECR) is the U.K.’s sustainability reporting framework. The regulation came into effect on April 1, 2019. SECR reporting is part of annual reporting, so disclosures are due at the time of a company’s regular annual reporting cycle. SECR reporting periods run for 12 months, so if your company uses an 18-month financial year, you will still need to publish SECR reports every 12 months.
ISSB
The new go-to framework shaping many reporting regulations comes from the International Sustainability Standards Board (ISSB). In 2023, the ISSB finalized two new global standards — General Requirements for Disclosure of Sustainability-related Financial Information (IFRS S1) and Climate-related Disclosures (IFRS S2). While the ISSB can’t impose requirements on any jurisdiction or company, its new standards are designed to serve as a foundation for regulations across international borders, and many countries are already incorporating them into their reporting regimes. Entities that plan to publish annual reports in 2025 using ISSB standards will want to track activities beginning in January 2024. The ISSB has stipulated that in the first year of reporting, entities will be permitted to focus on disclosing climate-related risks and opportunities, expanding into other areas of sustainability in January 2025.
Voluntary Reporting
The mandatory reporting requirements outlined above have evolved from a foundation of voluntary frameworks that businesses have used over the past decade to share their climate data with investors and other stakeholders. The most common voluntary reporting avenues include:
Sustainability Reports
Many companies choose to produce standalone sustainability reports that provide detailed information about climate-related risks, initiatives, and performance metrics. These reports are generally released on an annual basis at the discretion of the disclosing company. For example, Apple voluntarily publishes an annual sustainability report detailing its carbon emissions and progress toward climate goals.
TCFD
The Task Force on Climate-Related Financial Disclosures (TCFD) is a foundational framework which companies like Microsoft have historically used for voluntary reporting.
However, the TCFD is now being replaced by ISSB standards. In January 2024, the Financial Stability Board — the body responsible for the formation of the TCFD — officially sunsetted the entity, passing the baton to ISSB. The ISSB will now carry on TCFD’s legacy in providing the primary framework for climate disclosure. Companies can continue to use TCFD guidance if asked, but the ISSB will be the global standard moving forward.
CDP
Over the past two decades, CDP has come to represent the gold standard for voluntary environmental reporting. In 2023, more than 23,000 companies (representing $67T USD in market capitalization) disclosed their environmental performance data to CDP. Adobe is one example of a company that reports to the CDP and has earned an “A” grade from the organization for its sustainability work.
The window to submit responses to the annual CDP Climate Change questionnaire can vary from year to year, so it’s advisable to check the CDP's timeline page regularly throughout the year. Here are key dates for CDP disclosure in 2024:
- April 16: Platform open for authorities requesting disclosure
- April 30: Questionnaire becomes available
- June 4: Questionnaire opens for corporate response
- September 18: Scoring deadline for corporates
- October 2: Corporate disclosure ends
CDP has announced that, from 2024, it will incorporate the ISSB climate disclosure standard [S2] into its disclosure system.
Ready to start measuring your emissions? Learn out more about Persefoni’s AI-powered carbon accounting tool.
Preparing for Climate Reporting: 5 Essential Steps
Many mandatory reporting requirements are already in effect — or coming soon. Businesses need to put systems in place to ensure their emissions data is transparent, traceable, and reliable. There are several key steps you can take to prepare for reporting:
Step 1: Identify Relevant Regulations and Standards
Before you can report on your climate footprint, you need to identify which regulations you’re subject to, along with any voluntary frameworks you want to follow. All new policy mandates, along with the ISSB standards, build off of the GHG Protocol and TCFD framework, so getting comfortable with these frameworks will put companies in a good position to meet a variety of reporting requirements. In addition, companies may want to consult the PCAF for guidance on emissions measurement in finance, and the CDP or SBTi for reporting consistency. Aligning with the right frameworks will streamline carbon accounting and ensure a systematic approach to disclosures.
Step 2: Establish Organizational Boundaries and a Governance Strategy
To establish organizational boundaries, you’ll need to define the extent of your responsibility for greenhouse gas emissions, based on the equity share or control approach. This process will determine the proportional emissions responsibility for different entities and identify direct and indirect emissions (scopes 1 and 2).
You will also need to create a clear governance strategy. Climate reporting necessitates board oversight and calls for reliable data collection processes and ongoing risk assessment. You’ll need to coordinate with stakeholders across departments early on in the process, allowing time to address any data collection challenges.
Step 3: Identify Emissions Sources and Collect Data
The process of identifying emissions sources and collecting GHG data can differ significantly across scope categories. Scope 1 and 2 emissions, involving direct and indirect sources, can be relatively straightforward to measure through fuel use or utility invoices. However, scope 3 emissions are more complex. These calculations require you to identify relevant categories, prioritize data collection based on emissions and operational risks, and choose between spend, distance, or fuel-based approaches for estimation.
To streamline data collection and ensure accuracy, Climate Management and Accounting Platforms (CMAPs) like Persefoni offer automated solutions that facilitate data upload, calculations, and reporting for all emission scopes. These tools aid compliance by providing a transparent carbon ledger for audits and assurance.
Step 4: Implement a Climate Strategy
The fourth step in managing GHG emissions is to implement a climate strategy. Your strategy should address the impacts of climate risks and opportunities on your business. It should also incorporate short and long-term resilience plans, integrate climate considerations into decision-making, and disclose governance around these decisions. Key actions within strategy development will include:
- Benchmarking against peers
- Engaging stakeholders
- Assessing materiality
- Setting targets
- Planning emissions reductions
Businesses might also potentially make public commitments to reduction initiatives through organizations like SBTi. Regardless of how they report, companies are advised to start with easily manageable emissions (scope 1 and 2). They should also prioritize “hotspots” — the areas where they can make the most significant impact on total emissions. They can use this progress to engage stakeholders and drive innovation while justifying investments through disclosed co-benefits and returns on investment.
Step 5: Report Your Carbon Footprint
As you prepare to report to regulators and key stakeholders, it will be critical to ensure that the data you are disclosing is sound and can withstand scrutiny. It’s essential to establish solid internal controls and systems — including software systems that fortify the integrity of your reported data.
There’s a new high bar for climate reporting. In 2024, many businesses will need to respond to climbing expectations and requirements from a variety of entities, and robust systems for tracking and calculating carbon emissions are crucial. Persefoni’s ledger-based tool can help you prepare by ensuring your data is reliable, traceable, and transparent.
To learn more on how to get started with your climate reporting program, read our Climate Disclosure Starter Guide.
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