ISSB Launches Nature Disclosure Consultation as California's GHG Deadline Looms

ISSB Publishes Nature-Related Disclosure Exposure Draft

In one of the most significant sustainability reporting developments of the week, the International Sustainability Standards Board released a consultation draft on nature-related disclosures on October 22, 2026, timed to coincide with COP17 of the Convention on Biological Diversity, currently taking place in Yerevan, Armenia. Reported by Investment Executive and The Asian Banker, the draft proposes requirements in the form of an IFRS Sustainability Practice Statement, with a comment period running through February 19, 2027.

The ISSB's approach is deliberate: rather than issuing a standalone nature standard or amending the existing IFRS S2 climate framework, the board chose a Practice Statement that sits alongside IFRS S1 and S2 without altering either. The draft draws heavily on the Taskforce on Nature-related Financial Disclosures (TNFD) framework, with an emphasis on dependencies on natural systems, water, land use, supply chains, and ecosystem degradation risks. Companies would not need to apply the Practice Statement to claim compliance with ISSB Standards, but where nature-related risks are material, IFRS S1 already demands disclosure — the new guidance is designed to make that disclosure more consistent and decision-useful for capital markets.

ISSB Chair Emmanuel Faber has been direct on this point, stating that nature disclosure under IFRS S1 is not optional. The consultation will also ask stakeholders whether a Practice Statement is the right instrument, leaving open a path to a more binding standard-based outcome in the future. More than 44 jurisdictions have already adopted or are in the process of adopting ISSB Standards, giving the consultation draft broad global reach.

California SB 253: First GHG Reports Due November 10

Back in the United States, corporate sustainability officers face a pressing domestic deadline. On October 12, 2026, the California Office of Administrative Law approved the California Air Resources Board's initial regulation implementing SB 253, the Climate Corporate Data Accountability Act, effective immediately. As reported by Proskauer, Akin Gump, and Thompson Hine, this finalizes November 10, 2026 — just over two weeks away — as the first deadline for Scope 1 and Scope 2 greenhouse gas emissions reports.

SB 253 covers U.S.-formed entities doing business in California with more than $1 billion in annual revenue. For this first cycle, companies may rely on emissions data already in their possession as of December 5, 2024, or submit a statement of non-reporting. Scope 3 reporting requirements are scheduled to begin in 2027. Meanwhile, the companion law SB 261, which requires climate-related financial risk disclosures for companies above $500 million in revenue, remains on hold pending a Ninth Circuit appeal, according to Thompson Hine.

SEC Climate Rules Headed for Full Rescission

At the federal level, the trajectory runs in the opposite direction. The Securities and Exchange Commission has published a formal proposal to rescind its March 2024 climate disclosure rules in their entirety, according to reporting by Faribai. Those rules — which would have mandated GHG emissions and climate risk disclosures for public companies — never took effect due to immediate legal challenges. The SEC's proposal cites both authority concerns and cost as justification, underscoring the sharp divergence between state-level climate disclosure momentum and the current federal posture.

What It Means

The simultaneous arrival of the ISSB's nature consultation draft, the California SB 253 deadline, and the SEC's rescission proposal illustrates the fragmented but accelerating global landscape of climate and environmental disclosure. Companies operating across jurisdictions face an increasingly complex compliance matrix: mandatory GHG reporting in California, voluntary-but-signaled nature disclosure under IFRS, and a federal vacuum in the U.S. that state rules are rapidly filling.