EU: EFRAG Invites Engagement on Voluntary Sustainability Standard Beyond CSRD
On March 24, 2026, the European Financial Reporting Advisory Group (“EFRAG”) launched a call for expressions of interest from companies and other stakeholders to help shape the European Commission’s forthcoming standard—namely, the voluntary sustainability reporting standard for non-small- and medium-sized enterprises (“SMEs”) not subject to the Corporate Sustainability Reporting Directive (“CSRD”). According to EFRAG, the European Commission is expected to issue the standard as a delegated act, and the standard will be based on the Voluntary Standard for SMEs, which the European Commission adopted as a recommendation in July 2025. This development follows the EU’s Omnibus I reforms, which, as we reported here, significantly narrowed the scope of mandatory CSRD reporting.
EFRAG’s call for expressions of interest, which remains open until April 20, 2026, is directed at companies that are not SMEs but that would fall outside the revised CSRD scope. Planned engagement activities include webinars, surveys, interviews, and events designed to assess how sustainability reporting practices are evolving across Europe and how the new voluntary standard could be applied in practice.
Links:
EFRAG Press Release
EFRAG Voluntary Sustainability Reporting Resources
EU: Norway Pensions Manager Releases Nature Expectations Report
On March 19, 2026, Norges Bank Investment Management (“NBIM”), which manages the $2.1 trillion Norwegian Government Pension Fund Global, published its Nature Expectations report. The report details how NBIM expects portfolio companies to assess, disclose, and manage environmental and social dependencies, risks, and opportunities.
NBIM’s report addresses board oversight and strategy integration, policies on habitat protections, risk assessment, and supply chain transparency, among other considerations. The report clarifies that these expectations underpin NBIM’s stewardship activities, including engagement, proxy voting, and board oversight mechanisms.
The report is based on the understanding that “nature degradation already poses material risks” to NBIM’s portfolio and provides additional, ecosystem-specific expectations pertaining to land, freshwater, and the ocean, based on established and “emerging international standards for nature risk management and conservation.”
Links:
NBIM – Nature Expectations
Expectations Report
U.S.: California Regulator Holds Public Workshop on Implementation of Climate Disclosure Program
On March 23, 2026, the California Air Resources Board (“CARB”) held a virtual public workshop with stakeholders in connection with developing California’s Corporate Greenhouse Gas Reporting Program under the state’s climate-related financial risk disclosure laws, “S.B. 253” and “S.B. 261,” respectively. Starting in 2026, S.B. 253 will require U.S.-based business entities with revenues exceeding $1 billion and doing business in California to annually disclose their greenhouse gas emissions; S.B. 261 requires biennial disclosure of climate-related financial risks. The purpose of the workshop was to gather input from the public before issuing formal regulations, as a “pre-rulemaking” exercise.
S.B. 253 contemplates reporting in three thresholds: Scope 1, which captures direct emissions; Scope 2, which captures indirect emissions from consumed energy; and Scope 3, which captures indirect upstream and downstream greenhouse gas emissions. Reporting obligations for Scope 1 and 2 will begin on August 10, 2026, and reporting of Scope 3 emissions will follow in 2027.
During the workshop, CARB proposed its rulemaking approach on key topics, including accounting methods, emissions factors, and organizational boundaries. CARB solicited feedback on whether emissions should be accounted for based on a company’s percentage ownership of an operation or whether a company should account for 100% of emissions for operations over which it has control. CARB also specified that it would develop reporting templates for its Scope 1 and 2 reporting programs in 2027 and solicited feedback on what it should consider in finalizing the templates. Additionally, CARB requested public comment on proposed categories for Scope 3 reporting, which include purchased goods and services, employee commuting, leased assets, and downstream transportation and distribution.
S.B. 253 and S.B. 261 have been the subject of significant litigation since their enactment in 2023. S.B. 261, which requires climate risk reporting for companies in scope, continues to be stayed pending a decision in an appeal before the Ninth Circuit Court of Appeals. CARB has noted that, pursuant to a court order, it is not currently enforcing S.B. 261, and climate-related financial risk reporting under that statute is currently voluntary. S.B. 253 is not stayed at this time.
CARB will accept informal comments until June 1, 2026.
Links:
Climate Disclosure Meetings and Workshops
CARB Presentation Slides
Notice of Public Hearing
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