Your Quick Scrub
- Federal reporting rules are changing: While the SEC rules and California’s SB 261 are currently stayed, California’s SB 253 statutory deadlines remain set for 2026.
- Compliance is now a capacity crisis: Most in-house teams lack the bandwidth to handle carbon accounting alongside GAAP reporting.
- Audit readiness starts today: Even though CARB has relaxed “limited assurance” for the 2026 filing, waiting to collect data risks non-compliance when full requirements take effect.
For many mid-market CFOs, the SEC’s decision to pause its climate disclosure rules in April 2024 offered brief relief [1].
It might feel like a reprieve, but don’t be fooled.
While Washington waits for litigation, key U.S. states and international regulators are moving forward. The regulatory landscape isn’t gone, it’s fractured. The real question for 2026 isn’t whether you need to report. It’s who on your team has the bandwidth to handle it.
The "Federal Shield" has Shifted
The biggest mistake a leader can make is assuming that legal pauses mean a permanent break from compliance.
While the regulatory landscape has fractured, California’s SB 261 (Financial Risk) is temporarily paused by the Ninth Circuit Court of Appeals, delaying the January 1, 2026 enforcement. SB 253 (Emissions), however, remains active. Companies must continue reporting their greenhouse gas emissions.
Here is the reality check on the current statute as of late 2025:
- SB 261 (Financial Risk): Currently stayed pending the outcome of the appeal. While the immediate January 1, 2026 deadline is on hold, the law has not been struck down. Prudent companies are maintaining their climate risk assessments internally to be ready if the stay is lifted.
- SB 253 (Emissions): The mandate remains active. CARB has proposed a reporting deadline of August 10, 2026, for Scope 1 and 2 emissions.
This means the “data collection year” is still effective now. To report accurate 2025 data by August 2026, you must be tracking your energy usage and fleet emissions today. If you aren’t, you are already behind.
Beyond California, the EU’s Corporate Sustainability Reporting Directive (CSRD) applies to companies with major EU partners. They will require your emissions data to meet Scope 3 obligations, effectively creating a global reporting standard, regardless of U.S. court decisions.
The Operational Gap: A Capacity Crisis
Compliance is no longer just a policy issue. It is a capacity crisis. Even if your organization is committed to sustainability, your finance team is likely already stretched thin.
According to Bank of America’s 2024 Business Owner Report, while 87% of mid-sized business owners anticipate revenue growth, they cite labor shortages and the challenge of attracting talent as persistent operational headwinds [3].
In this tight market, asking your financial controller to “figure out ESG” alongside their day job is a strategic risk. Carbon accounting isn’t just “accounting with trees.” It requires a specialized skill set combining engineering-style estimation with financial rigor.
The "Carbon Accounting" Skill Set
To understand the gap, compare the daily workflow of a Financial Controller with the demands of Carbon Accounting:
- Data Sources:
- Financial: Structured data from ERP systems, bank feeds, and invoices.
- Carbon: Unstructured “activity data”: utility bills from 20 different locations, fuel receipts, refrigerant purchase logs, and supplier spend reports.
- Calculation Logic:
- Financial: Precision-based (Debits = Credits).
- Carbon: Estimation-based. You must select the correct “emission factor” (e.g., kg CO2e per kWh) for each specific grid region and fuel type. Using an outdated factor for your data year will invalidate your report.
- Audit Trail:
- Financial: established via SOX controls and approval workflows.
- Carbon: Often non-existent. Data is frequently trapped in email chains or loose spreadsheets without version control.
Most in-house teams are built for GAAP compliance, month-end closes, and tax reporting. They are not staffed to hunt down utility data or audit supplier emissions. Adding these massive workstreams to an overburdened team doesn’t just risk burnout; it risks degrading the quality of your core financial reporting.
The Scope 3 Trap
The biggest operational hurdle, and the one most teams underestimate, is Scope 3 emissions.
Scope 1 (direct emissions) and Scope 2 (purchased energy) are manageable; the data usually sits within your own four walls. Scope 3 covers everything else: your supply chain, business travel, waste, and the use of your sold products.
For most companies, Scope 3 accounts for over 70% of their total footprint. Collecting this data is a logistical nightmare that involves:
- Supplier Engagement: You have to ask hundreds of vendors for their emissions data. Most won’t have it.
- Data Gaps: When vendors can’t provide data, you have to estimate it using “spend-based” methods (calculating emissions based on the dollar amount spent). This is imprecise and often overstates your impact.
- Upstream vs. Downstream: You aren’t just looking back at what you bought; you have to model forward to calculate the emissions your products will generate during their lifespan.
The "Assurance Cliff"
There is a hidden financial risk to this operational ambiguity. The market is still confused about how to allocate ESG costs, often leading to “band-aid” solutions, like tracking data in disparate spreadsheets without internal controls.
This builds “technical debt” that will come due very soon.
Both California’s SB 253 and the EU’s CSRD have built-in requirements for third-party assurance.
- Limited Assurance: While CARB has indicated they will not require limited assurance for the initial 2026 report (allowing for a “good faith” transition year), it will be mandatory for subsequent filings. The auditor states they are “unaware of any material modifications” needed.
- Reasonable Assurance: Required by 2030. The auditor affirmatively states the data is accurate, the same standard as a financial audit.
Spreadsheets do not survive reasonable assurance.
If your carbon data is scattered across spreadsheets like Final_v3_UPDATED.xlsx, you risk audit failures. Start building a proper documentation trail now. Auditors need to see change logs, data lineage, and approval timestamps. They need to know who changed a conversion factor and why.
The “Assurance Cliff” is that moment when auditors ask for the evidence trail behind your emissions numbers. If that trail is riddled with errors or lacks documentation, the cost to remediate those filings (and the reputational damage of a restatement) will far exceed the cost of doing it right the first time.
From Compliance to Value
While the immediate driver is compliance, there is a strategic upside to getting this right. Companies that treat carbon accounting with the same rigor as financial accounting often uncover significant value:
- Cost of Capital: Lenders and investors are increasingly factoring climate risk into their rates. Clean, assured data can lower your cost of capital.
- Operational Efficiency: You can’t manage what you don’t measure. Tracking energy data often reveals inefficiencies in facility management or logistics that, when fixed, directly improve the bottom line.
- Customer Retention: As your largest customers face their own Scope 3 mandates, they will prioritize vendors who can provide accurate, primary data over those who cannot.
Your Action Playbook
To navigate this fractured landscape without overloading your staff, take a practical, step-by-step approach:
- Assess Materiality & Jurisdiction: Don’t guess. Determine exactly which mandates (CA SB 253, SB 261, CSRD) apply to you today. Check your revenue thresholds and your subsidiary locations.
- Audit Your Talent Bandwidth: Be honest. Can your team absorb 80-100 hours a month of data collection without slipping on core duties? If the answer is “no,” do not just add it to the Controller’s pile.
- Establish Internal Controls Early: Treat carbon data like financial data. Build the documentation trail now. Document your methodology, your emission factor sources, and your estimation logic.
- Centralize Your Data: Move away from loose spreadsheets. Whether you use a dedicated carbon accounting platform or a structured data warehouse, ensure there is a “single source of truth.”/
- Decide: Build vs. Buy: Instead of hunting for a full-time ESG Controller in a tight market, consider a fractional model. Outsourcing technical components, like carbon footprint calculation and regulatory mapping, gives you instant access to expertise without the fixed overhead.
How Scrubbed Can Help
Navigating the intersection of accounting and sustainability reporting is complex, but you don’t have to do it alone. Scrubbed’s Sustainability Services team acts as your fractional expert. We look beyond the raw data to guide your reporting strategy, ensuring compliance with major frameworks like GRI, SASB, and TCFD, while preparing you for the evolving demands of IFRS and ESRS. From mapping Scope 3 emissions to establishing audit-ready controls, we ensure your disclosures align with both California mandates and global standards. Reach out for an exploratory call to discuss your operational readiness.
ABOUT THE AUTHOR
John Mark Respeto is Scrubbed’s Sustainability and Quality Director. A Philippine CPA and former PwC Assurance Senior Manager, he bridges sustainability reporting with deep US GAAP / IFRS expertise across healthcare, mining, retail, and O&G. His mission: translate emerging disclosure mandates into pragmatic steps that help executives stay compliant and unlock value.
Sources:
- U.S. Securities and Exchange Commission. (2024, April 4).
Commission stays the enhancement and standardization of climate-related disclosures for investors.
https://www.sec.gov/corpfin/announcement/commission-stays-enhancement-standardization-climate-related-disclosures/ - California Legislative Information. (2023, October 7).
SB-261 Greenhouse gases: climate-related financial risk.
https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202320240SB261 - Bank of America. (2024, May 1).
2024 Business Owner Report: Mid-sized business owners anticipate revenue growth.
https://business.bofa.com/en-us/content/2024-business-owner-report.html - New Private Markets. (2024, October 14).
Data snapshot: Who pays for ESG expenses?.
https://www.newprivatemarkets.com/data-snapshot-who-pays-for-esg-expenses/
