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

ISSB Opens Global Consultation on Nature-Related Disclosures

On October 22, 2026, the International Sustainability Standards Board (ISSB) published an Exposure Draft proposing an IFRS Sustainability Disclosure Practice Statement 1 — Nature-related Disclosures, formally opening a global consultation that runs until February 19, 2027. The move is one of the most significant expansions of the ISSB's disclosure agenda since it issued IFRS S1 and S2 in 2023.

Rather than issuing a standalone nature standard or amending IFRS S2, the ISSB chose the lighter-touch route of a Practice Statement — non-mandatory in form but carrying real weight because IFRS S1 already obligates companies to disclose material nature-related risks and opportunities. The Practice Statement would set out exactly how companies should meet that pre-existing obligation. ISSB Chair Emmanuel Faber was direct on the point, stating that nature disclosures are not optional under existing rules and that the new guidance will clarify how companies comply.

The draft draws heavily on the framework developed by the Taskforce on Nature-related Financial Disclosures (TNFD), which has since wound down its own technical work program. Key disclosure themes include a company's dependencies on natural systems, the location of nature-related impacts, effects on Indigenous Peoples and local communities, and how these factors translate into material financial risks and opportunities. The ISSB is also asking stakeholders whether a voluntary Practice Statement is the right vehicle, or whether a mandatory standalone standard should follow — a question that will shape global nature-reporting rules for years to come. Individual jurisdictions could choose to make the Practice Statement mandatory within their own regulatory frameworks.

California's November 10 GHG Deadline: Weeks Away

Closer to home, U.S. companies are contending with the most imminent hard deadline in corporate climate disclosure: California's first Scope 1 and Scope 2 greenhouse gas emissions reports under SB 253 are due November 10, 2026 — just fifteen days away. The California Office of Administrative Law approved CARB's Initial Regulation on October 12, giving it immediate legal effect and locking in the deadline. Law firms including Proskauer Rose, Thompson Hine, and Akin Gump have all flagged the urgency for potentially covered companies.

SB 253 applies to U.S.-organized companies doing business in California with more than $1 billion in annual revenue — both public and private. For this first reporting cycle only, companies may rely on Scope 1 and 2 emissions data they already held or were collecting as of December 5, 2024. Firms without such data may submit a statement of non-reporting on company letterhead. Scope 3 reporting will not be required until 2027. CARB's voluntary Report Intake Platform is available for submissions, though use of the platform is optional while the underlying deadline is not.

Meanwhile, the companion law SB 261 — which would require climate-related financial risk disclosures from companies with over $500 million in revenue — remains suspended pending a Ninth Circuit appeal, according to Thompson Hine. And at the federal level, the SEC has proposed rescinding its 2024 climate disclosure rule in its entirety, citing authority and cost concerns, after that rule never took effect due to legal challenges.

The Bigger Picture

Taken together, this week's developments underscore the increasingly fragmented global landscape of climate and nature disclosure: the ISSB is carefully expanding its framework without disrupting existing adopters; the EU's revised ESRS — cutting mandatory datapoints by roughly 61% under the Omnibus reforms — entered the Official Journal in September and takes force November 10; and in the U.S., state-level action in California is filling the vacuum left by a retreating federal regulator. Companies operating across these jurisdictions face the challenge of navigating overlapping, and sometimes diverging, disclosure regimes simultaneously.