The Environmental Protection Agency’s (EPA) proposed rollback of the Greenhouse Gas Reporting Program (GHGRP) including 40 CFR part 98 subpart RR (Subpart RR) created uncertainty with respect to the requirements to qualify...more
With the initial August 10, 2026, reporting deadline approaching, the California Air Resources Board (CARB) hosted its fourth public workshop on March 23, 2026, and focused on implementing the Climate Corporate Data...more
Despite federal pullback on ESG requirements, state and international ESG mandates persist, with new obligations coming into play in 2026. For corporate directors and ESG officers, compliance failures may carry both financial...more
Hyperscale data centers being developed to provide energy for artificial intelligence (AI) are forcing a change in the clean-energy conversation. “Hyperscalers” refers to large technology companies that build, own or procure...more
Maritime biofuels are “making waves” in 2026. Growing decarbonization efforts have the potential to create synergies between the maritime and biofuel sectors. Industry stakeholders should be aware of several international,...more
The U.S. Department of the Treasury and the Internal Revenue Service (IRS) recently released proposed regulations under section 45Z of the Internal Revenue Code of 1986, as amended (Section 45Z). Section 45Z provides a...more
In 2023, California passed Senate Bill 253 (SB 253) and Senate Bill 261 (SB 261).
SB 253 requires U.S. companies with annual revenues over $1 billion that do business in California to report their greenhouse gas (GHG)...more
On December 1, 2025, the New York State Department of Environmental Conservation (DEC) adopted regulations establishing a mandatory greenhouse gas (GHG) reporting program. DEC enacted Part 253 pursuant to the State’s Climate...more
In September, we provided a Bracewell Update discussing the California Air Resources Board’s (CARB’s) Preliminary List of Reporting/Covered Entities relating to the state’s climate disclosure laws—the California Corporate...more
On September 12, 2025, the U.S. Environmental Protection Agency (EPA) proposed to narrow the Greenhouse Gas Reporting Program (GHGRP) significantly, citing Executive Orders aimed at deregulation. The Proposal would eliminate...more
The California Air Resources Board (CARB) released a list this week identifying which entities the agency believes are subject to the state’s climate disclosure laws — SB 253 and SB 261. The list can be downloaded here....more
9/26/2025
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Task Force on Climate-related Financial Disclosures (TCFD)