During the week of September 11, 2023, the California Legislature passed a series of bills known collectively as the “California Climate Accountability Package” (“CCAP”). The CCAP is comprised of three bills: S.B. 252 (applicable only to two California state pension funds, and not discussed further herein), S.B. 253 (the “Climate Corporate Data Accountability Act” of “CCDA”) and S.B. 261 (the “Climate-Related Financial Risk Act” or “CFRA”). If Governor Newsom follows through on his stated intention to sign the entire CCAP into law, and if the package survives the inevitable legal challenges that are sure to come, these new disclosure laws could prove to be highly disruptive to companies across the United States—many of which are likely unaware it impacts them.
