What matters to me today is disclosure risk.
119 days. California’s first climate-related disclosures are due in 119 days. As I’ve noted, if you haven’t started preparing the disclosures, you’re already late.
But CARB is signaling a light touch on this initial round of disclosures — “limited” enforcement, just a “good faith effort.” Whew! Well, . . . maybe.
If you are subject to the mandates of SB 253 and SB 261 — i.e., “doing business in California” and meet the revenue thresholds — not disclosing isn’t an option. But what is the risk of disclosing?
As noted, for this round, the risk of regulatory enforcement is not great. But once your performance, your numbers go public, what then? Make no mistake, disclosure is just the start.
People and groups, NGOs in particular, will be watching. And comparing. And don’t forget, California’s legislative mandate is carbon neutrality by 2045. These initial disclosures will confirm what we already know — we are nowhere close to being able to hit that mandate.
These disclosures are about far more than counting emissions. This is core business risk management. When your numbers and risks are published side-by-side with your peers, how do you fare? When CARB and the state move past mere disclosure to cuts necessary to hit statutory mandates, will you be ready? Will disruption of your enterprise be the objective of activists?
Yes, light enforcement begins in 119 days. Risk management considerations and analysis are long overdue if they haven’t already started. Let’s discuss.
That’s what matters to me today in 250 words or less. What matters to you? I’d really like to know.