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California SB 261: Climate-Related Financial Risk Act·Disclosure SB261-CLIMATE-RISK

Climate-related financial risk disclosure

Guide pratique pour préparer cette information. Utilisez cette fiche pour identifier les données à préparer, vérifier les affirmations et organiser les preuves. Pour les exigences exactes, reportez-vous toujours à la source officielle CARB.

Passeport publié

Révision en attente
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Norme

California SB 261: Climate-Related Financial Risk Act

Disclosure SB261-CLIMATE-RISK · 2026-initial-regulation-as-amended-sb219

En vigueur

2023-10-07

Source officielle : Ouvrir ↗

Dernière révision

Support pédagogique LRA · Non publié ni approuvé par CARB

Objet de l’information

This disclosure asks an organisation to explain how climate-related risks could affect its finances, strategy and operations, and how it is managing those risks. In practice, the report should focus on the main risk types the organisation faces, the time horizons it uses to think about them, and the actions it is taking to assess, reduce or respond to those risks.

The practical emphasis is usually on the organisation as a whole, not just a few high-profile sites. That means looking across relevant operations, assets, supply chains and business activities where climate risk could matter, rather than limiting the discussion to flagship locations or isolated examples.

Ce support pédagogique LRA aide à préparer l’information. Pour les exigences exactes, reportez-vous toujours à la source officielle CARB.

Avant de commencer

Avant de commencer

Une courte liste de contrôle avant de préparer cette information — cochez chaque point une fois réglé.

Préparation

Informations clés à préparer

Champ à préparer Ce qu’il faut recueillir Indice de preuve Responsable
Capital and investment risk Capture the climate-related threats that could affect invested capital, financing decisions, or the value of financial holdings, with a clear note of the affected asset, exposure, and why it matters. Risk register, treasury or investment committee papers, portfolio review notes, and scenario analysis outputs. Treasury / finance
Customer demand risk Capture how climate-related change could alter customer buying patterns, product take-up, or service demand, including which customer groups or channels are affected. Commercial forecasts, sales pipeline reviews, customer research, and product planning papers. Commercial / sales
Workforce health risk Capture climate-related threats to worker wellbeing and safety, including the activities, sites, or roles exposed and the nature of the hazard. Health and safety assessments, incident logs, site risk reviews, and occupational health reports. Health and safety / HR
Market stability risk Capture climate-related effects that could disturb wider market conditions or economic performance, and explain the channel through which the business could be affected. Macro risk papers, market analysis, finance committee materials, and external economic outlooks. Strategy / finance
Operating disruption risk Capture climate-related threats that could interrupt day-to-day business activity, including the process, site, or function exposed and the likely disruption. Business continuity plans, operational risk logs, site resilience reviews, and incident reports. Operations
Physical climate risk Capture the material climate hazards that could directly affect assets, sites, or activities, and note whether the issue is acute or longer-lasting. Physical risk assessment, asset location maps, insurance reviews, and climate scenario analysis. Risk / sustainability
Supplier disruption risk Capture climate-related threats to the flow of goods or services from suppliers, including which tier, route, or dependency is exposed. Supplier risk assessments, procurement reviews, logistics reports, and continuity plans. Procurement / supply chain
Risk timing bands Capture when each climate-related risk is expected to matter, using the organisation’s short, medium, and long planning windows consistently across all risks. Risk methodology, planning assumptions, strategy papers, and scenario analysis timeframes. Strategy / risk
Transition climate risk Capture the material climate-related threats arising from the move to a lower-carbon economy, including the policy, technology, market, or reputation channel involved. Transition risk assessment, regulatory watchlists, strategy papers, and scenario analysis outputs. Risk / sustainability
+ Afficher les sous-éléments de SB261-CLIMATE-RISK (liste de travail LRA)

Comment le préparer

Set the reporting boundary first: decide which parts of the business, assets, investments, operations, and supply network are in scope for this climate-risk review, and keep that scope consistent across the disclosure.
Sort the risks into the required themes using plain business language: impacts on capital and investments, customer demand, staff health and safety, markets and wider economic conditions, day-to-day operations, supply chains, and both physical and transition-related climate risks.
Gather support for each theme before drafting: use internal records, risk registers, incident logs, scenario work, management papers, and any other source that shows why the risk matters and how it was assessed.
Prepare the actual disclosure content for each required area, making sure you cover the short-, medium-, and long-range view and explain the risk in a way that is specific enough for a reader to understand the exposure.
Record any exclusions, assumptions, scope changes, or updates to your approach, so the reader can see what was left out, what changed, and why the final wording matches the evidence you used.
Check the draft against the official source before sign-off: confirm every required risk area is addressed, the time horizons are included, and the final text still matches the underlying evidence and scope decisions.

Demander les données

Request the climate risk evidence from Risk / ERM

Traduisez l’information en une question métier interne, puis adaptez-la au vocabulaire de votre organisation.

What climate-related risks could affect the business, and how are they described across the organisation’s main risk categories and time horizons?

Use your organisation’s own risk language first, then map it to the disclosure categories. For example, ask for the risks your teams already track in risk registers, scenario work, business continuity, or strategic planning, rather than using framework labels in the first ask. Check the official source before sign-off.

Demande faible

Please provide the climate-related financial risk disclosure evidence for the reporting period, including physical and transition risks and all material categories.

Pourquoi elle échoue : It uses framework language first, which can force the owner to translate before they can answer. It also does not point to the organisation’s own risk records, so the response may be incomplete or hard to trace back to source documents.

Meilleure demande

Please send the latest risk register extract, scenario analysis, or board paper for [reporting period] covering the climate risks your team already tracks for [entity/boundary]. Use your internal risk names first, and include anything that affects investments, customers, people, operations, suppliers, markets, and the time windows you use for planning. Please add the source file, owner, last update date, and a short note on how each risk was assessed.

Modèle d’e-mail formel
Subject: Request for climate risk evidence for [reporting period]

Hi [name/team],

We are preparing the climate risk section for [reporting period] and need your help with the underlying evidence.

Please send the latest material you hold on climate-related risks for [entity/boundary], using your own internal risk terms. In particular, please include anything you have on:
- risks to investments or capital allocation
- risks to customer demand or sales
- risks to people health and safety
- risks to markets or wider economic conditions
- risks to operations and service delivery
- physical climate impacts
- risks to suppliers and logistics
- transition-related risks
- the time windows you use for near, mid, and longer term planning

For each item, please include the source file or system, the date last updated, the owner, and a short note on how the risk was assessed.

If you already have a risk register extract, scenario pack, board paper, or similar, that would be ideal. Please send by [date].

Thanks,
[preparer name]
Version courte pour Teams / Slack
Hi [name/team] — could you share the latest climate risk evidence for [reporting period] for [entity/boundary]? Please use your own risk terms and send any register extract, scenario pack, or board paper covering impacts on investments, customers, people, operations, suppliers, markets, and physical/transition risks, plus the time windows used. Please include source, owner, and last update date. Thanks — [name]

Exemples sectoriels

Manufacturing

Contexte. A plant-heavy business with exposed sites, logistics dependencies, and supplier concentration.

Demande adaptée. Please share the latest operational risk pack for [reporting period] covering weather-related site disruption, equipment damage, utility interruptions, supplier delays, and any transition risks affecting production, logistics, or capital spend. Use the names your operations and risk teams already use, and include the source pack, owner, last review date, and planning horizon.

Exemple de réponse. A risk register extract listing site flood exposure, heat-related downtime, supplier route disruption, and energy cost sensitivity, with references to the quarterly ERM review and the business continuity tracker.

Financial services

Contexte. A lender or investor with exposure through portfolios, counterparties, and market conditions.

Demande adaptée. Please send the latest risk paper for [reporting period] covering climate-related impacts on portfolios, counterparties, market conditions, client demand, and operating resilience. Please use the terms your credit, investment, and risk teams already use, and include the source paper, owner, review date, and the time windows used in planning.

Exemple de réponse. A committee paper summarising portfolio sensitivity to flood and heat exposure, client sector demand shifts, and transition pressures on selected counterparties, with links to scenario analysis and the risk dashboard.

Rédigez votre information

Des notes qui transforment les données en information publiée

Modèles pédagogiques LRA — adaptez-les à votre organisation et vérifiez la source officielle avant validation.

Note méthodologique

The disclosure should explain the basis used to identify and group climate-related financial risks, including how the organisation distinguished physical from transition exposures and how it assigned them to short, medium and long time periods.

Note de contexte

The figures should help readers understand where climate-related financial risk is concentrated, which parts of the business or value chain are most exposed, and whether the main concerns are immediate or longer dated.

Déclaration sur les variations

If the profile changes from one period to the next, the reporter can note whether that reflects a revised assessment, a change in business activity, updated climate assumptions, or movement in the timing or severity of the risks.

Entrée de l’index de contenu

SB261-CLIMATE-RISK Climate-related financial risk disclosure — [location / page] / [notes]

Centre de téléchargement

Outils et formulaires de préparation

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Préparation à l’assurance

Pour chaque affirmation, vérifiez les preuves

Affirmation Risque Preuves à vérifier
We based the coverage figure on the operations and activities we actually reviewed, and we can show how we decided what was in and out.An assurer will test whether the boundary was set consistently, whether exclusions were deliberate, and whether the figure could be overstated or understated by selective coverage.Boundary memo, inclusion/exclusion list, management sign-off, source population listing, and any reconciliation between the reviewed population and the reported figure.
We used the same reporting approach across the disclosed areas, and we can point to the framework note that guided how the information was assembled.An assurer will check whether the preparation basis was applied consistently and whether the report really follows the stated reporting approach rather than a mix of methods.Reporting methodology paper, framework mapping, internal guidance, version-controlled draft, and evidence of review against the chosen reporting basis.
We checked the disclosed area for climate-related financial exposures affecting people and invested assets, and we would note clearly if nothing material was found.An assurer will probe whether the assessment covered the right population and asset base, whether materiality was judged consistently, and whether a ‘none identified’ statement is supportable.Risk assessment workbook, materiality criteria, workshop notes, asset and workforce lists, and sign-off from the relevant business owners.
We documented the actions already in place to lessen the exposure and to adjust our plans, and we can trace each action back to the risk it was meant to address.An assurer will test whether the response measures are real, current, and linked to the risks described, rather than being generic or aspirational.Action tracker, project plans, control descriptions, budget approvals, implementation evidence, and ownership records for each measure.
Where our reporting was not fully complete, we explained the gaps, set out what we could support at the time, and recorded the next steps for filling the missing pieces.An assurer will check whether omissions were clearly explained, whether the partial disclosure is honest about limitations, and whether there is a credible plan to improve completeness.Gap log, rationale for omissions, draft-to-final change log, improvement plan, and evidence of follow-up actions or assigned owners.
We used the time bands we had defined in advance when assessing the disclosed risks, and we can show how those periods were applied in the analysis.An assurer will probe whether the chosen periods were set before the assessment, applied consistently, and matched the way the risk analysis was actually performed.Time-horizon methodology, planning papers, risk assessment outputs by period, and evidence that the same bands were used across the disclosure.

Dossier de preuves à préparer

Lacunes fréquentes dans les rapports

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.

Lacunes fréquentes

Erreurs à éviter lors de la collecte des données

Wrong ownerChasing the board pack team for operational climate risk inputs leaves the data owner out of the loop, so the evidence comes from the wrong desk.
Framework language instead of business termsAsking teams for transition and physical risk in framework wording makes them translate twice, which often produces inconsistent source data.
No clear boundaryCollecting figures without stating which entities, sites, or activities are in scope leads to mixed populations that cannot be compared cleanly.
+ Afficher 6 de plus

Là où un jugement professionnel est souvent nécessaire

Set the reporting perimeter after acquisitions or disposalsUse the group boundary that matches the period you are reporting, and if a business has been bought or sold during the year, explain whether its risks are included for the full period, part of the period, or excluded, with the same approach applied across the risk areas you cover.
Choose one way to handle different country definitionsWhere local teams use different labels or thresholds for the same climate risk, map them to a single internal description for the disclosure and explain any country-by-country differences so readers can see how the organisation has aligned them.
Decide how to treat activities that sit just inside or outside scopeFor sites, entities, products or suppliers near the boundary, state the rule you used to include or exclude them and explain any cut-off or practical threshold so the treatment is consistent and understandable.
+ Afficher 5 de plus

Exemples

Exemples illustratifs

Synthétiques, rédigés par LRA — ils ne proviennent ni d’un rapport d’entreprise ni du texte d’une norme.

Illustrative (synthetic) example — Power and utilities

We describe how climate-related risks could affect our business over the near, middle and longer term, separating weather-driven losses from transition pressures. - Physical hazards could disrupt generation sites, damage grid assets and raise repair spend; in this example, £18m of the £30m estimated exposure is near term, £9m is medium term and £3m is long term, with the same profile also affecting employee safety and the continuity of our operations and supply chain. - On the transition side, policy, technology and market shifts could reduce customer uptake, weaken asset values and tighten financing conditions; here, £12m of the £20m estimated exposure is near term, £6m is medium term and £2m is long term, with knock-on effects for capital deployment, consumer demand, financial markets and the wider economy.

This example shows a utility-style reporter linking weather damage and transition pressure to operations, workers, suppliers, customers, investment value and broader market conditions across three time horizons.

Illustrative (synthetic) example — Food manufacturing

We explain how climate-related risks may affect our group across short, medium and longer horizons, using separate estimates for weather-related and transition-related pressures. - Physical events such as heat, flood and water stress could interrupt production, affect staff wellbeing, and strain inbound ingredients and packaging; in this example, £9m of the £15m estimated exposure is short term, £4m is medium term and £2m is long term. - Transition pressures, including changing regulation, customer preferences and financing conditions, could reduce demand, pressure margins and lower the value of planned investments; here, £6m of the £10m estimated exposure is short term, £3m is medium term and £1m is long term, with possible spillovers into our operations and the broader economy.

This example shows a manufacturer describing physical and transition risks in plain language, with separate time buckets and clear links to demand, investment value, worker safety, supply continuity and market-wide effects.

Rapports d’entreprises

Comment les entreprises publient SB261-CLIMATE-RISK en pratique

Exemples de pratiques de publication complètes et partielles. Ce sont des analyses fondées sur des preuves, non des modèles à recopier.

Rapports réels publiés
Owens Corning
Building Products · United States · 2024
Ouvrir le rapport →
Owens Corning’s 2024 Sustainability Report provides evidence on employee health and safety risks related to climate change, noting that exposure potentials are assessed against established limits to quantify risk (p.62). The report includes related context on climate-related risks impacting financial planning and revenues, as well as a mention of developing a climate transition plan, though no detailed disclosures or headline values are provided for transition risks (pp.356–357). However, the report does not contain clear disclosures on financial market risk, operations risk, physical risks, supply chain risk, or time horizons, with several key risk areas either missing or only partially addressed.
CSX Corporation
Ground Transportation — Railroads · United States · 2024
Ouvrir le rapport →
CSX Corporation’s 2024 Sustainability Report references climate-related risks within its enterprise-level risk management program and mentions long-term climate-related risks with Risk Leaders (p.48). The report also indicates alignment with leading ESG disclosure frameworks such as GRI 2021 Universal and references integration of climate change measures consistent with SDG 13.2 (p.4). However, the report does not provide clear disclosures on specific SB261 climate risk categories including consumer demand risk, employee health and safety risk, financial market risk, operations risk, physical risks, supply chain risk, time horizons, or transition risks.
Sands China Ltd.
Hotels, Restaurants, Leisure, Tourism Services · Macao · 2025
Ouvrir le rapport →
Sands China Ltd.’s 2025 ESG Report includes a general environmental risk assessment process aligned with best practices and notes that climate-related risks are evaluated, with risk assessment conducted up to the year 2100 (pp. 22, 32). The report mentions climate-related opportunities related to operating costs and sustainable service options, and governance responsibility for ESG issues is delegated to the board of directors (pp. 29, 32). However, the report lacks clear disclosures on specific climate-related financial risks such as capital investment risk, financial market risk, operational risk, physical risks, supply chain risk, and time horizons, and the discussion of consumer demand risk is unclear (p. 33).

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Scénarios à travailler

A preparer is drafting the climate-risk section for a group with manufacturing sites, a lending book, and a large retail customer base. The team has notes on flood exposure at two plants, possible changes in customer buying patterns, and a review of how weather events could affect deliveries.

QHow should the preparer decide which risk themes to cover so the disclosure is complete enough for review?
Afficher la réponse type →

A finance lead has prepared a short paragraph saying the company faces weather-related disruption, but it does not say when those effects are expected to show up. The risk team has separate notes for near-term, mid-range, and longer-range planning.

QWhat should the preparer do about timing when describing the risk?
Afficher la réponse type →

A company has identified a possible shift away from a carbon-intensive product line, but the draft only mentions a general strategic concern. It does not explain whether the issue could affect revenue, financing, or asset values.

QHow should the preparer frame this issue in the climate-risk disclosure?
Afficher la réponse type →

A preparer has a draft that lists storm damage at one site and heat stress for warehouse staff, but the supply-chain team says a key supplier in another region could also be disrupted by the same weather pattern. The draft does not yet mention that supplier dependency.

QWhat should the preparer do before finalising the risk narrative?
Afficher la réponse type →

Références au référentiel

Exigences California applicables et informations connexes

Références disponibles du référentiel et informations voisines utiles à la préparation de cette exigence.

California

SB261-CLIMATE-RISK

au sein de California SB 261 : Climate-Related Financial Risk Act

Ouvrir la source officielle →

Connexes et exploration

Plus dans California SB 261 → Parcourir le catalogue complet → Accueil de la Bibliothèque des informations → Rechercher dans toutes les informations →

FAQ

Questions auxquelles cette page répond

How do I use the SB261-CLIMATE-RISK page to prepare a first draft of the climate-related financial risk disclosure?+
What data do I need to gather for SB261-CLIMATE-RISK before I start writing the disclosure?+
How should I scope the SB261-CLIMATE-RISK disclosure so I do not miss a risk area?+
Who should own the SB261-CLIMATE-RISK data collection and sign-off process?+
What evidence pack do I need to build for SB261-CLIMATE-RISK assurance readiness?+
What are the six assurance claims I need to check for SB261-CLIMATE-RISK?+
What are the most common mistakes people make when drafting SB261-CLIMATE-RISK?+
How do I use the SB261-CLIMATE-RISK workbook download to build the disclosure?+
Can I use the SB261-CLIMATE-RISK example disclosures as a template for my own report?+
How does the SB261-CLIMATE-RISK page relate to ESRS E1, and can I reuse the same data?+

Autres questions auxquelles cette page peut aider

Aller plus loin · SB261-CLIMATE-RISK

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