---
title: "Record which climate-disclosure instruments are in force before any gap list"
url: "https://ailawframework.com/practice/climate-esg-and-sustainability-reporting/build-a-climate-disclosure-gap-list-from-the-data-room/united-states"
type: "task_jurisdiction_version"
site: "AI Law Framework"
id: "A48-R20260922-2-US"
practice_area: "Climate, ESG & Sustainability Reporting"
tier: "yellow"
lawyer_review: "required"
jurisdictions: ["US"]
last_reviewed: "2026-10-22"
---

# Record which climate-disclosure instruments are in force before any gap list

> Make a table with the instrument the lawyer names and the status sentence copied from the page the lawyer opens. Do not draft disclosure.…

Canonical page: https://ailawframework.com/practice/climate-esg-and-sustainability-reporting/build-a-climate-disclosure-gap-list-from-the-data-room/united-states  
Last reviewed: 2026-10-22

Site index for agents: https://ailawframework.com/llms.txt

## Key facts

| Fact | Value |
| --- | --- |
| Practice area | [Climate, ESG & Sustainability Reporting](https://ailawframework.com/practice/climate-esg-and-sustainability-reporting.md) |
| Human involvement | Yellow: Lawyer and AI draft together |
| How AI is used | Make a table with the instrument the lawyer names and the status sentence copied from the page the lawyer opens. Do not draft disclosure. Do not turn the March 2024 SEC climate rules into a checklist of required contents. |
| What the lawyer must review | SEC press release 2026-49, dated 29 May 2026, says the Commission proposed to rescind the climate-related disclosure rules in their entirety. The release states that the Commission stayed those rules on 4 April 2024, voted on 27 March 2025 to end its defense, and that on 12 September 2025 the Eighth Circuit held the petitions in abeyance until the Commission reconsiders the rules or renews its defense. Do not build a gap list as if those rules were in force. California is separate. CARB's page says the SB 253 greenhouse-gas program and the SB 261 climate-related financial-risk program are under development. It describes SB 253 as covering U.S.-formed entities doing business in California with annual revenue over $1 billion, and SB 261 as covering public and private U.S. companies doing business in California with annual revenue of $500 million. The same page describes 2026 Scope 1 and Scope 2 reporting resources and a proposal to move a Scope 1 and 2 deadline from 10 August 2026 to 10 November 2026 if the initial regulation is approved by the Office of Administrative Law. You confirm that status before anyone reports. |
| Written for | United States |
| Applies to | [Build a climate-disclosure gap list from the data room](https://ailawframework.com/practice/climate-esg-and-sustainability-reporting/build-a-climate-disclosure-gap-list-from-the-data-room.md) |

## Checking plan

- What the AI does: Make a table with the instrument the lawyer names and the status sentence copied from the page the lawyer opens. Do not draft disclosure. Do not turn the March 2024 SEC climate rules into a checklist of required contents.
- Basis: Checked against the linked sources on 22 October 2026. Confirm the current instrument before reliance.

## Notes

- The SEC proposal is not itself a repeal. The release says the rules were already stayed.
- CARB cites Health and Safety Code § 38532 for SB 253. Confirm whether the cited initial regulation has been approved before relying on a form or a date.

## Sources

- [SEC press release 2026-49, proposal to rescind the climate-related disclosure rules (29 May 2026)](https://www.sec.gov/newsroom/press-releases/2026-49-sec-proposes-rescission-climate-related-disclosure-rules) (checked 2026-10-22)
- [California Air Resources Board: corporate greenhouse-gas reporting and climate-related financial risk](https://ww2.arb.ca.gov/our-work/programs/california-corporate-greenhouse-gas-reporting-and-climate-related-financial-risk) (checked 2026-10-22)

*Practice guidance for planning and review. Confirm current primary sources and the requirements of the actual matter. This is general information, not legal advice.*