What’s coming for sustainability compliance in 2026
After a year of transition, what does 2026 have in store for sustainability compliance?
• 3 min read
Would have been nice if sustainability compliance’s 2025 horoscope had warned us about the trials ahead.
This year, the SEC essentially dropped its proposed climate disclosure rule, while the EU watered down its ESG compliance. Some called it the year of greenhushing, in which companies continue to work to combat climate change but don’t go out of their way to publicize it. Other companies truly did retreat from commitments. And the US didn’t attend the COP30 global climate negotiations in November.
What does all this mean for the future? Brigham McNaughton, partner in sustainability at PwC, thinks that sustainability compliance in 2026 will be the year of “interoperability.” In the context of sustainability, interoperability means ensuring that financial and other data can be exchanged between different software systems, reporting agencies, and overlapping frameworks.
“What are the processes, tools, governance to be able to look through that for any slices or cuts that I need for individual jurisdictions?” McNaughton added.
McNaughton told us his clients previously expected that as the SEC put climate disclosure regulations in place, they would have fewer redundant, varied, and piecemeal disclosure rules to deal with. But with the SEC rule mostly moot, CFOs, sustainability officers, and compliance teams are having to figure out a new strategy: finding “the most efficient way to thread the needle across the different disclosure obligations,” he said.
With that in mind, here are three sustainability disclosure developments to keep an eye on for 2026.
The EU’s corporate sustainability disclosures. Climate disclosures across the pond were slashed in 2025, as the threshold for what size companies have to report was increased from 250 to 1,000 employees, drastically reducing the number of businesses that must report to the EU.
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California’s rules. The most populated state in the country has two climate disclosure laws coming online in 2026. But the one that would require companies with over $500 million in revenue to outline their financial risks due to climate change starting in January, SB 261, has been put on hold by a November court injunction. The court did not impede the second law concerned with greenhouse gas emissions (SB 253), requiring companies with over $1 billion in revenue to report scope 1 and scope 2 emissions from last year. That one goes into effect in August.
Extended Producer Responsibility. Speaking of patchwork rules, add this to your rolodex of acronyms: EPR, or extended producer responsibility. This approach, requiring companies to be financially responsible for the collection and end-of-life management of their products and packaging, has been sweeping the country since 2021. Several states—including Maine, Oregon, California, Maryland, Washington, Minnesota, and Colorado—have passed (slightly different) EPR laws.
“We’re really seeing the rumblings of movement,” McNaughton said, “and the realization that the intersection of supply chain transparency and compliance pressure, and how the need for traceability, consistency, the need for governance and early detection…leads to resilience. If I really do have a deeper understanding of my supply chain, of the fragility of the practices, that’s a competitive advantage.”
Now what does your 2026 horoscope say?
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CFO Brew helps finance pros navigate their roles with insights into risk management, compliance, and strategy through our newsletter, virtual events, and digital guides.