Climate reporting in the United States has entered a pivotal phase. In 2025, the ESG landscape is defined by federal regulatory reversals, assertive state legislation, intensifying litigation, and global standard convergence. Companies are no longer asking if they should disclose climate-related data — they’re asking how to do so credibly, consistently, and defensibly.

🏛️ Federal Climate Disclosure Rule: Frozen, Possibly Rewritten

The SEC’s climate disclosure rule, adopted on March 6, 2024, was a landmark attempt to standardize climate-related disclosures. It required public companies to report Scope 1 and 2 emissions, climate-related risks, governance structures, and financial impacts under Item 1500 of Regulation S-K and Article 14 of Regulation S-X.

However, the rule was voluntarily stayed on April 4, 2024, following nine legal challenges consolidated in the Eighth Circuit. On February 11, 2025, Acting SEC Chair Mark Uyeda requested courts delay oral arguments, citing:

• Economic harm to capital markets
• Lack of statutory authority
• A regulatory freeze under the Trump administration

Implications:

• The rule is unlikely to be implemented under current leadership.
• Companies should prepare for state-level mandates and investor-driven standards instead.

📎 SEC Climate Disclosure Rule Update – NatLawReview
📎 SEC Rule Summary – Lythouse

🏛️ State-Level Climate Disclosure Laws: The New Vanguard

With federal action stalled, states are stepping up. California’s SB 253 and SB 261 have become the blueprint for climate disclosure legislation nationwide.

🟢 California:

• SB 253: Scope 1, 2, and 3 emissions disclosure for companies with >$1B revenue
• Scope 1 & 2: Reporting starts 2026
• Scope 3: Reporting starts 2027

• SB 261: Climate-related financial risk disclosures for companies with >$500M revenue
• Deadline: January 1, 2026

• July 1, 2025: CARB rulemaking deadline
• December 5, 2024: Enforcement discretion announced for first-year reporting

🟡 New York (SB 3456):

• Introduced: January 27, 2025
• Scope 1 & 2: Reporting starts 2027
• Scope 3: Reporting starts 2028
• Assurance: Limited (2027) → Reasonable (2031)

🟠 Colorado (HB 25-1119):

• Scope 1 & 2: 2028
• Scope 3 (partial): 2029–2031
• Includes opt-out clause on free speech grounds

🔵 New Jersey (SB 4117):

• Scope 1 & 2: 2029
• Scope 3: 2030
• Assurance: Reasonable by 2033

🟣 Illinois (HB 3673):

• Rulemaking deadline: July 1, 2026
• Reporting begins: January 1, 2027

📎 State-Level Climate Disclosure Breakdown – Compliance & Risks

⚖️ Climate Litigation: Courts as Climate Enforcers

Litigation is reshaping climate reporting as much as legislation. In 2025, several high-profile cases are testing the boundaries of corporate accountability.

Featured Cases:

• Bayamón v. Exxon Mobil Corp.: RICO and antitrust claims allowed to proceed in Puerto Rico
• Chamber of Commerce v. CARB (Feb 3, 2025): Federal court dismissed Supremacy Clause and extraterritoriality challenges to California’s SB 253 and SB 261
• New York v. Exxon Mobil (Jan 2025): Greenwashing claims dismissed — court ruled consumers were not misled due to public awareness of fossil fuel impacts
• New Jersey v. Exxon Mobil (Feb 2025): State claims dismissed as federally pre-empted under Clean Air Act
• Anne Arundel County v. BP (Jan 2025): Maryland court dismissed climate damages claims, citing federal jurisdiction

📊 Climate Data Trends: NOAA, IPCC, and Scientific Reports

Scientific data continues to drive urgency and policy reform.

NOAA Monthly Reports:

• June 2025: Record heat in Southwest; intensified drought in Midwest
• Spring 2025: Coldest in a decade across Northern US
• Hurricanes and wildfires: Frequency doubled over two decades

Scientific Reports:

• IPCC Sixth Assessment (2025): Warns of 2.7°C rise by 2100
• Global Carbon Project: 5% drop in global emissions; renewables now >50% of global electricity
• WMO Report: 30% increase in climate-related disasters over 10 years
• Lancet Countdown: 25% rise in climate-related health issues

🌐 Global Influence: CSRD, ISSB, and EU Shifts

International frameworks are reshaping US climate reporting indirectly.

CSRD (EU):

• January 2025: First wave of CSRD reporting begins
• July 2025: EU Taxonomy expands to new sectors
• Mid-2025: EU proposes “Omnibus Regulation” to simplify sustainability laws

ISSB:

• IFRS S1 & S2 gaining traction in UK, Canada, Japan
• US multinationals preparing for dual compliance

📎 ESG Disclosure Guide – ASUENE

🧭 Strategic Imperatives for 2025

Climate reporting is no longer a passive exercise. It’s a dynamic, high-stakes arena where companies must:

• Map state-level mandates and timelines
• Prepare Scope 3 data systems and assurance pathways
• Align with CSRD and ISSB for global consistency
• Monitor litigation risks and greenwashing exposure
• Engage with regulators during rulemaking windows
• Invest in scenario analysis and climate governance

In 2025, transparency isn’t just a virtue — it’s a survival strategy.

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