[35700]
May 06, 2024
TO: ESG Advisory GroupSEC Rules Committee RE: ICI Planned Advocacy on California Climate Accountability Package
Governor Newsom signed into law the "California Climate Accountability Package" on October 7, 2023.[1]
Under the Climate Corporate Data Accountability Act, reporting entities doing business in California will have to annually disclose their Scopes 1 and 2 greenhouse gas emissions (beginning in 2026) and Scope 3 greenhouse gas emissions (beginning in 2027) to the California Air Resources Board (CARB), pursuant to regulations to be developed by CARB. Under the Climate‐Related Financial Risk Act, any covered entity must report, by January 1, 2026 (and biennially thereafter), their climate-related financial risk as well as steps undertaken to reduce such risks.
ICI plans to send letters to Governor Newson and state legislators advocating that: 1) investment companies be excluded from the reporting requirements of both Acts; and 2) consistent with the Greenhouse Gas Protocol, reporting on managed assets be permitted but not required.
Joshua Weinberg
Associate General Counsel, Securities Regulation
Notes
[1] For a summary of California's Climate Accountability Package, see ICI Memo 35482 (Oct. 10, 2023), available at https://www.ici.org/memo35482. The legislation has been challenged in court. For a summary of the legal challenge, see ICI Memo 35606 (Jan. 21, 2024), available at https://www.ici.org/memo35606.