Global Climate Disclosure Rules Diverge as Companies Face a Fragmented 2026 Landscape

In 2026, global corporations are entering a new era of climate risk disclosure defined by increasing complexity and scope. Despite years of progress toward consensus, regulatory actions taken by the United States and the European Union last year have steered them onto divergent paths, exacerbating regional policy fragmentation. Simultaneously, however, a growing number of jurisdictions worldwide are implementing new climate disclosure laws, compelling multinational companies to establish concrete governance processes to manage compliance data.

Background Analysis: A Shift in U.S. and EU Policy Winds

The core factors driving the current divergence are political shifts and policy adjustments in the leadership of the U.S. and EU. In the United States, following President Donald Trump's inauguration, the Securities and Exchange Commission (SEC), under Chair Paul Atkins, quickly sought to abandon the defense of the Biden-era climate-risk disclosure rule in court. Atkins is more broadly focused on deregulation for U.S.-listed companies, arguing that excessive rules create more friction than benefit. The rule has since been stayed by a federal appeals court and remains in limbo.

Meanwhile, the European Union also underwent a regulatory "rollback" in 2025. A proposal from the European Commission aimed to simplify corporate sustainability reporting laws. The final political agreement significantly raised the employee and revenue thresholds for the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD). It is estimated that this will remove 90% and 70% of companies from the scope of each directive, respectively, with reporting timelines delayed until 2028.

Global Trends: Disclosure Requirements Grow at Local and International Levels

Despite rollbacks at the federal level in the U.S. and EU, the disclosure pressure on companies has not diminished. Within the U.S., states like California and New York are leading the charge. Of California's two climate bills, SB 253, which requires companies with over $1 billion in annual revenue to report greenhouse gas emissions, remains in effect, with 94 companies having already submitted reports voluntarily. New York passed a law late last year requiring certain heavy-emitters in the state to disclose their greenhouse gas emissions.

On the international front, according to the International Sustainability Standards Board (ISSB), nearly 40 jurisdictions globally have adopted or are planning to adopt climate disclosure standards aligned with the ISSB's frameworks. Regulations are already active in the United Kingdom and Mexico, with laws in Australia and Spain set to go online this year.

Market Response: Investor Pressure Emerges as a Key Driver

In response to this complex regulatory environment, the market's reaction reveals an interesting dynamic. Carole Laible, CEO of Domini Impact Investments, noted that corporations have not rolled back their disclosures on a large scale. A survey by Morningstar Sustainalytics also shows that 55% of global asset owners view ESG regulation as a "net-help," with a plurality viewing the U.S. and EU rollbacks as "a step in the wrong direction."

Persistent pressure from investors is filling the vacuum left by regulation. "If you do have a lot of investors asking [for information] - and if it goes from a grassroots consumer to the highest level institutional investor - corporations start providing and disclosing that information," Laible said.

To navigate this fragmentation, many forward-thinking companies are actively "leveling up" their internal governance. For example, eBay has placed its ESG team, led by its Chief Sustainability Officer, within the finance office and established an ESG Disclosure Steering Committee to ensure agility in complying with global reporting standards. eBay's CSO, Renee Morin, stated that this is to better adapt to the evolving requirements of the EU, California, and other jurisdictions, describing it not as a "big leap" but more as "tweaking the systems." It has become clear that regardless of regulatory shifts, building robust internal data governance processes is now core to maintaining a competitive edge in the current landscape.