---
title: "Keep a climate narrative off the tool and list the gaps instead"
url: "https://ailawframework.com/practice/climate-esg-and-sustainability-reporting/draft-a-climate-disclosure-narrative-from-the-gap-list-and-the-source-pa/united-states"
type: "task_jurisdiction_version"
site: "AI Law Framework"
id: "A48-A20260923-1-US"
practice_area: "Climate, ESG & Sustainability Reporting"
tier: "red"
lawyer_review: "required"
jurisdictions: ["US"]
last_reviewed: "2026-10-22"
---

# Keep a climate narrative off the tool and list the gaps instead

> List missing topics in the client's source papers, as topics only. Write no disclosure paragraph, no risk-factor sentence and no board statement.

Canonical page: https://ailawframework.com/practice/climate-esg-and-sustainability-reporting/draft-a-climate-disclosure-narrative-from-the-gap-list-and-the-source-pa/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 | Red: Lawyer writes; AI may check, clarify or collect data |
| How AI is used | List missing topics in the client's source papers, as topics only. Write no disclosure paragraph, no risk-factor sentence and no board statement. |
| What the lawyer must review | Any climate narrative that would be filed or published is yours. SEC press release 2026-49, 29 May 2026, proposes to rescind the Commission's climate disclosure rules and states that they were stayed on 4 April 2024. Do not write as if those rules are in force. The CARB page is the California source that was opened: Senate Bill 253 for annual scope 1, 2 and 3 emissions by a U.S.-formed entity doing business in California with revenue above one billion dollars, and Senate Bill 261 for biennial climate-related financial risk by a public or private U.S. company doing business in California with revenue of 500 million dollars. Both programs are described as under development. Opinion 512 leaves the published words with you. |
| Written for | United States |
| Applies to | [Draft a climate-disclosure narrative from the gap list and the source papers](https://ailawframework.com/practice/climate-esg-and-sustainability-reporting/draft-a-climate-disclosure-narrative-from-the-gap-list-and-the-source-pa.md) |

## Checking plan

- What the AI does: List missing topics in the client's source papers, as topics only. Write no disclosure paragraph, no risk-factor sentence and no board statement.
- Basis: Checked against the linked sources on 22 October 2026. Confirm the current instrument before reliance.

## Notes

- A topic list is not a draft paragraph with the prose removed.
- Australian sustainability-report contents were not used.

## Sources

- [SEC press release 2026-49, proposal to rescind 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)
- [ABA Formal Opinion 512, Generative Artificial Intelligence Tools (29 July 2024)](https://www.americanbar.org/content/dam/aba/administrative/professional_responsibility/ethics-opinions/aba-formal-opinion-512.pdf) (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.*