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ESG disclosure & reporting11 min read

ESG disclosure after the rollback: what still binds you

Three columns sorting climate disclosure instruments into those paused or stayed, those still binding, and the measurement rules that nothing changed.Three columns sorting climate disclosure instruments into those paused or stayed, those still binding, and the measurement rules that nothing changed.

Between March 2025 and August 2026 most of the climate disclosure calendar that companies had been budgeting against came apart. Not all of it. The parts that survived are narrow, specific, and mostly not the parts people remember from the 2024 planning cycle.

What follows is a ledger rather than an argument. What collapsed, what is still standing as at 30 August 2026, and which of it reaches a company headquartered in Canada or the United States that is not listed in the European Union. Where a fact is proposed rather than final, this article says so in the sentence that states it. Where a date is on a court's timetable, it says that too.

The eighteen months that emptied the calendar

DateWhat happened
6 March 2024The SEC finalized its climate-related disclosure rules
4 April 2024The Commission stayed its own rules pending Eighth Circuit litigation
18 December 2024The CSSB published CSDS 1 and CSDS 2
27 March 2025The SEC voted to end its defense of the rules
23 April 2025The CSA paused its mandatory climate disclosure work
12 September 2025The Eighth Circuit held the petitions in abeyance
18 November 2025The Ninth Circuit enjoined SB 261 pending appeal
9 January 2026Oral argument in the SB 261 appeal, with the stay left in effect
18 March 2026The Omnibus I Directive entered into force in the EU
3 June 2026The SEC's proposed full rescission reached the Federal Register
3 August 2026The comment period on the proposed rescission closed

Read that column top to bottom and it looks like a general retreat. The impression is broadly right and locally wrong, and the local exceptions are where the remaining work sits.

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