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California SB 261: Climate-Related Financial Risk Act·Disclosure SB261-FRAMEWORK-ALIGNMENT
TCFD or equivalent framework alignment
Practical guidance for preparing this disclosure. Use this card to identify the information to prepare, verify claims and organise supporting evidence. For exact requirements, always refer to the official CARB source.
Published passport
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Prepared from official source material and published report evidence. No named approver is recorded yet, so this page carries no byline.
Use it alongside the official CARB source while that review is in progress.
Standard
California SB 261: Climate-Related Financial Risk Act
Disclosure SB261-FRAMEWORK-ALIGNMENT · 2026-initial-regulation-as-amended-sb219
Last reviewed
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LRA educational guidance · Not issued or endorsed by CARB
To prepare this disclosure
Disclosure focus
This disclosure asks an organisation to explain which recognised climate-risk framework it uses, or how its own approach lines up with one, when reporting on climate-related financial risk. In practice, the focus is on showing that the organisation has a structured way to identify, assess, manage and disclose climate risks and opportunities, rather than giving a general sustainability narrative.
The practical emphasis is usually on the whole organisation, not just a few flagship locations or isolated projects. A useful response should make clear whether the framework covers the full business, including relevant operations and decision-making processes, and whether any parts are excluded or only partially covered.
This LRA educational guidance supports disclosure preparation. For the exact requirements, always refer to the official CARB source.
Before you start
Before you start
A quick mental checklist before you prepare this disclosure — tick each as you settle it.
Preparation
Key information to prepare
| Preparation field | What to capture | Evidence hint | Owner |
|---|---|---|---|
| Equivalent basis used | Record which other reporting basis the company is relying on for this filing, and enough detail to show it is the basis actually used for the disclosure. | Cross-check the selected basis against the published report or framework statement used for the filing. | Sustainability reporting / Legal |
| Reporting framework chosen | Capture the named reporting framework the company says it has followed for this disclosure, with the exact framework title used in the report. | Tie the entry back to the framework named in the report cover, methodology note, or disclosure index. | Sustainability reporting |
| Governance disclosure flag | Confirm whether the report includes the governance-related climate disclosure set out under the referenced framework, and capture the yes/no status used for filing. | Check the governance section of the report and the disclosure checklist or index. | Sustainability reporting / Governance |
| Targets and metrics flag | Confirm whether the report includes the climate metrics-and-targets disclosure set under the referenced framework, and capture the yes/no status used for filing. | Review the metrics, targets and KPI sections together with the disclosure index. | Sustainability reporting / Finance |
| Risk process flag | Confirm whether the report includes the climate risk-management disclosure set under the referenced framework, and capture the yes/no status used for filing. | Check the risk management narrative in the report and the disclosure checklist or index. | Risk management / Sustainability reporting |
| Strategy disclosure flag | Confirm whether the report includes the climate strategy disclosure set under the referenced framework, and capture the yes/no status used for filing. | Review the strategy section of the report and the disclosure index or checklist. | Strategy / Sustainability reporting |
＋ Show SB261-FRAMEWORK-ALIGNMENT sub-elements (LRA working checklist)
State which reporting framework you used.
Identify any equivalent reporting rule you relied on.
Confirm whether you provided the governance-related TCFD disclosure.
Confirm whether you provided the TCFD disclosure on metrics and targets.
Confirm whether you provided the TCFD disclosure on risk management.
Confirm whether you provided the TCFD disclosure on strategy.
How to prepare it
Choose the reporting basis first. Identify the climate-reporting framework you are relying on, and record the equivalent reporting basis used for this filing.
Map your content to the four required topic areas. Check that your disclosure covers governance, strategy, risk handling, and metrics plus targets, using the framework you selected.
Gather the supporting records before drafting. Pull together board or committee papers, management materials, internal reports, and any other source documents that show the information you will report.
Prepare the final disclosure in a clear, complete form. State the framework used and provide the required yes/no confirmation for each of the four topic areas, or the narrative and figures that support them.
Note any gaps, exclusions, or changes in approach. If you have left anything out or changed how information is presented, explain that clearly so the reader can see what was not included and why.
Check the draft against the official source before release. Confirm that the framework choice, the equivalent basis, and each topic-area disclosure match the source material and are internally consistent.
Request the data
Request the climate reporting evidence pack
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
Which reporting framework did we use, and can we show that our public climate report covers governance, strategy, risk handling, and metrics/targets for the period in scope?
Use your organisation’s own labels first, then map them to the climate reporting framework terms only when you prepare the disclosure. For example, ask for the board paper, risk register, climate plan, or KPI pack if those are the names your teams use. This is a possible LRA training template; adapt it to your organisation and check the source material before sign-off.
Weak request
Please confirm whether we are TCFD aligned and provide the governance, strategy, risk management, and metrics/targets disclosures.
Why it fails: This uses framework language only, so the owner may not know which internal documents to pull. It also does not specify the period, boundary, source system, or which approved materials should be returned.
Better request
Please send the latest approved climate reporting pack for [reporting period] for [entity/boundary], including the framework or approach used and the board, risk, climate plan, and KPI materials that support the sections on governance, strategy, risk handling, and metrics/targets. Include document title, version, date, approval status, source location, and any gaps. I will map your team’s labels to the disclosure wording.
Formal email template
Subject: Request for climate reporting evidence pack for [reporting period] Hello [name/team], I am preparing the climate disclosure pack for [reporting period] and need the supporting material for the public report or filing. Please send the following for [entity/boundary]: - the framework or approach we used for the climate report; - the source material that shows how the report covers governance, strategy, risk handling, and metrics/targets; - the latest approved version, plus any draft or redline if the published version is not yet available; - the document name, version, date, and where it is stored; - any note on gaps, exceptions, or sections handled by another team. Please use your team’s own document names and system labels. I will map them to the disclosure wording during preparation. This is a possible LRA training template; please adapt it to your organisation and check the source material before sign-off. Many thanks, [preparer name]
Short Teams / Slack version
Hi [name/team] — I’m pulling together the climate disclosure pack for [reporting period]. Could you share the latest board/risk/climate materials that show the framework used and the sections covering governance, strategy, risk handling, and metrics/targets for [entity/boundary]? Please include version/date, source location, and any gaps. I’ll map your team’s labels to the disclosure wording. This is a possible LRA training template; adapt it to your organisation and check the source material before sign-off.
Industry examples
Financial services
Context. The climate disclosure is assembled from board papers, enterprise risk reporting, and the annual report drafting pack.
Adapted request. Please share the approved board paper, risk committee pack, climate strategy note, and KPI dashboard for [reporting period] that show the framework used and the materials behind the governance, strategy, risk handling, and metrics/targets sections for [entity/boundary]. Include version, date, and file location.
Example response. Board paper v4 dated 18 Mar 2025; risk committee pack v2 dated 20 Mar 2025; climate strategy note v3 dated 15 Mar 2025; KPI dashboard FY2024; framework used: TCFD; gaps: none; source: board portal and shared drive folder [link].
Manufacturing
Context. The climate disclosure is built from operations, HSE, and finance inputs, with final sign-off in the annual report process.
Adapted request. Please send the latest approved climate report inputs from operations, HSE, and finance for [reporting period], including the framework or approach used and the documents showing how the report covers governance, strategy, risk handling, and metrics/targets for [plant/site/group boundary]. Include the file name, version, date, and any missing sections.
Example response. Operations climate pack v2 dated 02 Apr 2025; HSE risk register extract v5 dated 28 Mar 2025; finance KPI workbook FY2024; framework used: TCFD; gaps: strategy section pending final board wording; source: shared drive folder [link].
Draft your disclosure
Notes that turn data into a disclosure
LRA training templates — adapt them to your organisation, and check the official source before sign-off.
Method note
This disclosure is based on the reporting basis identified by the company and the framework it says it used, with each TCFD topic area marked according to whether the relevant information was provided.
Context note
Taken together, the data show which framework underpinned the disclosure and whether the report includes the main topic areas expected for a climate-related narrative.
Fluctuation statement
If the pattern changes from one period to the next, the reporter can explain that the shift reflects changes in the reporting basis, the scope of the framework used, or the extent to which each topic area was completed.
Content index entry
SB261-FRAMEWORK-ALIGNMENT TCFD or equivalent framework alignment — [location / page] / [notes]Download Centre
Preparation tools & forms
Professional preparation tools for SB261-FRAMEWORK-ALIGNMENT — free with an LRA Community membership. Register once (it's free) and every download unlocks, together with the Disclosure Library, templates and the LRA AI Assistant.
Assurance readiness
For each claim, check the evidence
| Claim | Risk | Evidence to check |
|---|---|---|
| We relied on a different reporting basis that we believe is acceptable for this filing, and we can show why it was chosen. | The assurer checks whether the basis was actually eligible, consistently applied, and not selected simply because it was convenient or incomplete. | Board or management approval of the chosen basis; a short rationale memo; mapping from the chosen basis to the disclosed content; any legal or technical review confirming eligibility. |
| We named the reporting basis we used in the published material, so readers can see what framework or rule set underpinned the disclosure. | The assurer probes whether the named basis matches the content, whether it was identified clearly, and whether the wording could mislead about what was actually used. | Final report wording; cross-check against the internal disclosure checklist; version history showing the named basis was retained through sign-off; reviewer comments on clarity. |
| We prepared the governance section using the same reporting approach throughout, and the underlying source material was aligned before publication. | The assurer looks for inconsistency between the stated approach and the actual governance content, or for missing support for parts of the section. | Draft-to-final comparison; source documents for governance statements; internal review notes; sign-off from the owner of the governance content. |
| Where our governance information was not complete, we explained the gap and set out what remains to be done. | The assurer checks whether the gap explanation is specific, whether the missing items are clearly identified, and whether the follow-up plan is realistic. | Gap log; action tracker; draft explanations for each omission; evidence of management review of the completion plan. |
| We prepared the metrics-and-targets section from the best information available at the time, and we kept a record of any limitations in the data. | The assurer probes whether the data were current, whether estimates or proxies were used appropriately, and whether limitations were disclosed rather than hidden. | Data source list; calculation files; notes on estimates, assumptions, or proxies; data quality review records; evidence of sign-off on the final figures. |
| We used the same reporting basis for the risk-management section as for the rest of the disclosure, so the narrative is internally consistent. | The assurer checks for mismatches between sections, unsupported claims about processes, or a risk story that does not fit the rest of the filing. | Cross-reference matrix between sections; process maps or policy extracts; internal consistency review; reviewer comments and resolution log. |
Evidence pack to prepare
Common reporting gaps
The information is presented without a date or as-at point.
The scope or boundary of the statement is left undefined.
Key terms are used inconsistently across the report.
Material changes since the previous period are not disclosed.
Assertions are made without supporting detail or a source record.
Boilerplate is used that does not actually answer what is asked.
Common gaps
Mistakes to avoid when collecting the data
Wrong ownerThe request goes to a team that does not hold the source records, so the answer is built from second-hand knowledge instead of the people who can trace it back.
Framework words too earlyThe team asks for the information in framework language rather than the organisation’s own terms, and the source owner cannot map the request to their records.
Scope left vagueNo one states which business units, entities, or activities are in scope, so different teams collect different slices of data that cannot be compared.
Wrong time basisThe data is pulled for the wrong reporting period or cut-off point, which makes the evidence line up with a different time than the disclosure.
Mixed counting basisOne source uses one counting method and another uses a different one, but the figures are merged anyway, so the final set is not internally consistent.
Source labels lostOriginal file names, system tags, or record labels are stripped away during collection, so the team cannot show where each figure came from.
Populations mergedGroups that should stay separate are combined too soon, which hides differences and makes later checks against the source records difficult.
Evidence details missingThe team keeps the numbers but not the supporting metadata, so the date, owner, version, or origin of the source cannot be verified later.
No approval trailThe collected pack moves forward without a clear sign-off record, so nobody can show who checked the data and when.
Where judgement is often needed
Choosing the reporting basis after a buy-in or sale-outSet the reporting boundary from the same cut-off date and group structure used in your wider reporting pack, then explain any additions or removals from acquisitions, disposals or reorganisations so readers can see why the comparison changed.
Reconciling different country-level definitionsWhere local teams use different labels or thresholds for the same topic, map them to one organisation-wide approach, state the mapping rule, and note any country exceptions that were kept for legal or operational reasons.
Deciding who sits just inside or just outside scopeFor entities, sites, funds or activities near the edge of your boundary, apply one documented inclusion rule consistently and disclose the main exclusions so users understand the line you drew.
Picking the timing point for the information setUse one clear reporting date or period-end across the disclosure, and if some inputs come from earlier or later internal closes, say so and explain the timing difference.
Using estimates where direct measurement is not availableWhen actual figures are missing, use a stated estimation method, identify the main assumptions, and flag which parts are measured and which are modelled or approximated.
Rounding and presentation of small differencesRound figures in a consistent way across the disclosure, keep the underlying calculation trail available, and note when totals may not exactly match because of rounding.
Protecting personal or sensitive data through groupingIf detailed location, workforce or customer information cannot be shown safely, aggregate it to a level that protects privacy while still explaining the basis for grouping and any material gaps it creates.
Handling mixed internal and external sourcesIf the disclosure combines company records with third-party or public data, identify which parts came from each source and explain any quality checks or limitations that affected the final wording.
Examples
Illustrative examples
Synthetic, written by LRA — not from a company report, not text from any standard.
Illustrative (synthetic) example — manufacturing
We rely on a climate-reporting framework that is accepted as equivalent for this filing, and we use that framework to organise the disclosure. - Governance: yes; strategy: yes; risk handling: yes; measures and targets: yes. - In practice, that means our board and committee oversight, our climate-related business planning, our risk process, and our emissions/target reporting are all covered in the package we publish.
This example shows a company in manufacturing saying it used an accepted equivalent climate framework for the filing and that all four TCFD-style content areas are covered.
Illustrative (synthetic) example — financial services
Our group uses a recognised climate disclosure route that we treat as equivalent for this report, and we present the information through that framework. - Oversight by directors and committees: yes; climate-related business planning: yes; risk identification and response: yes; performance measures and targets: no. - So, the report covers leadership, planning, and risk handling, but it does not include a full set of metrics and targets in this cycle.
This example shows a financial-services reporter using an equivalent route and disclosing three of the four content areas, while leaving out the measures-and-targets element.
Company reports
How companies report SB261-FRAMEWORK-ALIGNMENT in practice
Examples of full and partial reporting practice. These are evidence-led reviews, not exact disclosure templates to copy.
Sands China Ltd.
Hotels, Restaurants, Leisure, Tourism Services · Macao · 2025
Sands China Ltd.’s 2025 ESG Report provides covered disclosures on TCFD governance, noting that the board of directors has delegated authority on ESG-related issues (p.29), and on TCFD metrics and targets, including a 2025 target of a 17.5% decrease in Scope 1 and 2 absolute emissions (p.30-31). The report partially addresses TCFD strategy and framework use, mentioning a materiality assessment process and referencing frameworks like TCFD and SASB without headline values (p.27, 29). However, the disclosure on TCFD risk management is unclear, with risk assessments limited to present day and sea level rise only assessed for 2100, lacking a clear comprehensive risk management statement (p.32).
Owens Corning
Building Products · United States · 2024
Owens Corning’s 2024 Sustainability Report provides some related context on TCFD climate risks and opportunities, including references to governance (p.352) and risk management (p.361), but does not clearly disclose these elements. There is no clear evidence of disclosures on TCFD strategy or metrics and targets within the report. The report also lacks explicit mention of alignment with the SB261 framework or equivalent reporting requirements.
Cargill
Food Production — Agricultural · United States · 2025
Cargill's 2025 Impact Report provides some related context to the SB 261 disclosure requirements, including references to governance and climate-related risks and opportunities on pages 2 and 111, though these do not constitute clear or explicit disclosures of board oversight, strategy, or risk management as per the framework (pp. 2, 111). The report mentions a TCFD index on page 111 and discusses climate strategy and risk management in general terms but lacks specific, detailed disclosures on metrics, targets, or a formal framework alignment. Notably, there is no quotable evidence found regarding the use of a reporting framework or equivalent reporting requirements, and the clarity of governance and risk management disclosures remains uncertain.
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Scenarios to work through
A reporting team has prepared a climate section using a different recognised framework, but the draft only covers the organisation’s oversight arrangements and leaves out how climate issues affect the business model, how climate risks are handled, and any measures or targets.
QShould the team treat this as enough alignment for this disclosure, or do they need to check that the chosen framework covers the full set of climate topics they are relying on?
Reveal model answer →Hide answer ↑
They need to check the framework they are using against the full set of climate topics they plan to disclose. If they rely on a framework other than TCFD, it should still cover governance, strategy, risk handling, and measures and targets in a way that supports the disclosure; otherwise the alignment claim is too thin.
Why this matters · A substitute framework should support the whole climate story, not just one part of it.
A preparer has copied climate content from a group report that uses a recognised framework, but the local filing only includes the framework name and a short note saying the company follows it. The underlying sections are not clearly mapped to the four topic areas.
QIs naming the framework enough, or should the preparer make sure the disclosure shows where each climate topic is covered?
Reveal model answer →Hide answer ↑
Naming the framework alone is not enough if the filing does not show that the climate topics are actually covered. The preparer should make sure the disclosure clearly links the content to the relevant areas so a reader can see how the organisation’s governance, strategy, risk handling, and measures and targets are addressed.
Why this matters · Framework alignment should be visible in the content, not just stated as a label.
A sustainability lead is reviewing a draft that includes a detailed risk process and a set of emissions targets, but the board oversight section is still being finalised. The team wants to publish now and fill in the governance wording later.
QCan they treat the disclosure as complete if one of the framework areas is still missing?
Reveal model answer →Hide answer ↑
No. If they are relying on a framework-based alignment statement, the disclosure should be complete across the areas they are using. Leaving out the governance part means the reader cannot see the full basis for the alignment claim, so the team should finish that section before sign-off.
Why this matters · Do not present framework alignment as complete when a core topic area is still absent.
A company uses a climate framework that is not TCFD, but its draft report only says the framework was used and then gives a narrative on climate strategy. It does not explain how the chosen framework supports the disclosure or whether the same framework is used consistently across the climate section.
QWhat should the preparer check before relying on that framework in the filing?
Reveal model answer →Hide answer ↑
The preparer should check that the framework named in the filing is the one actually used to structure the climate disclosure and that it supports the topics being reported. If the organisation is using an equivalent approach rather than TCFD itself, the report should still make the basis for that choice clear and show the relevant climate content in a coherent way.
Why this matters · Be clear about which framework underpins the disclosure and use it consistently.
Framework references
Relevant California requirements and related disclosures
Available framework references and nearby disclosures relevant to preparing this requirement.
California
SB261-FRAMEWORK-ALIGNMENT
within California SB 261: Climate-Related Financial Risk Act
Related & explore
Covered entity applicability → CardClimate-related financial risk disclosure → CardImplementation fee and administration →Reporting gaps and completion plan →Biennial reporting timeline and enforcement status → Card
Browse all disclosures →
More in California SB 261 → Browse full catalogue → Disclosure Library home → Search all disclosures →
FAQ
Questions this page answers
For SB261-FRAMEWORK-ALIGNMENT, what do I need to have ready before I start drafting the disclosure?+−
The page gives a plain-language explainer and a step-by-step ‘how to prepare’ section, plus a short list of datapoints to prepare. Use those as the starting point so you can gather the right inputs before writing the draft.
What does the SB261-FRAMEWORK-ALIGNMENT page say I should decide first about scope and basis?+−
It points you to the ‘Equivalent basis used’ and ‘Reporting framework chosen’ datapoints, so you can be clear on the basis and framework before drafting. That helps keep the disclosure consistent from the start.
Which SB261-FRAMEWORK-ALIGNMENT datapoints should I collect from governance, targets, risk and strategy owners?+−
The page lists four flags to prepare: governance disclosure, targets and metrics, risk process, and strategy disclosure. Those are the main inputs to request from the relevant owners before you build the disclosure.
How do I use the SB261-FRAMEWORK-ALIGNMENT workbook to prepare the disclosure?+−
The Download Centre includes a Prep & Assurance workbook in .xlsx format. Use it to organise the preparation work and the assurance checks before turning the inputs into a draft.
What should go into the evidence pack for SB261-FRAMEWORK-ALIGNMENT assurance readiness?+−
The page includes an evidence pack with five items for assurance readiness. Use that pack to assemble the supporting material you will need to back up the disclosure and the claims you make.
What are the six assurance claims I need to verify on the SB261-FRAMEWORK-ALIGNMENT page?+−
The page says there are six assurance claims to verify, each with a claim, risk and evidence angle. Use those checks to test whether the draft is supportable before it goes any further.
What are the common reporting gaps or mistakes for SB261-FRAMEWORK-ALIGNMENT?+−
The page lists common reporting gaps and mistakes so you can spot weak points early. Use that section as a pre-submission check to avoid missing key inputs or leaving the draft too vague.
How do I turn the SB261-FRAMEWORK-ALIGNMENT data into a draft disclosure?+−
The page has a draft-output section with visualisation ideas, narrative starters and a content-index line. Those are there to help you turn the prepared data into a usable first draft.
Can I use the SB261-FRAMEWORK-ALIGNMENT example disclosures as a template for my own report?+−
The page includes synthetic illustrative examples, including a quantitative table, to show how the disclosure can look in practice. Treat them as examples only and adapt them to your own data so the numbers and narrative stay internally consistent.
How does the SB261-FRAMEWORK-ALIGNMENT page relate to ESRS E1, and can I reuse data across both?+−
The page says the closest ESRS correspondence is ESRS E1 (Climate Change). That means some data may be reusable across frameworks, but the page does not say the requirements are identical.
Where can I find real company report examples for SB261-FRAMEWORK-ALIGNMENT?+−
The page has a ‘From company reports’ table that links to real published reports at the pages where the topic is disclosed. Use it to see how others present similar material in practice.
More questions this page can help with
SB261-FRAMEWORK-ALIGNMENT checklist: what should I gather before drafting the disclosure?SB261-FRAMEWORK-ALIGNMENT workbook download: how do I use the .xlsx file for prep and assurance?What evidence do I need for SB261-FRAMEWORK-ALIGNMENT assurance readiness?How do I assign ownership for SB261-FRAMEWORK-ALIGNMENT data collection across governance, targets, risk and strategy?What are the common mistakes to avoid when preparing SB261-FRAMEWORK-ALIGNMENT?How do I use the SB261-FRAMEWORK-ALIGNMENT narrative starters and content-index line?Can I reuse climate data from ESRS E1 for SB261-FRAMEWORK-ALIGNMENT?What does the SB261-FRAMEWORK-ALIGNMENT plain-language explainer help me do?How should I set the equivalent basis used for SB261-FRAMEWORK-ALIGNMENT?What should I ask the data owner for the governance disclosure flag in SB261-FRAMEWORK-ALIGNMENT?What should I ask the data owner for the targets and metrics flag in SB261-FRAMEWORK-ALIGNMENT?Where can I find synthetic example disclosures for SB261-FRAMEWORK-ALIGNMENT?
Go deeper · SB261-FRAMEWORK-ALIGNMENT
Learn to prepare this disclosure end-to-end
This guide covers one statutory requirement. The California Climate Regulation course walks SB 253 and SB 261 end to end — applicability, GHG inventories, climate-risk reporting and assurance — with exercises on your own data.
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