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C O M P A R I N G O T H E R R E P O R T I N G R E Q U I R E M E N T S The SEC rule simply adds to the growing number of policies requiring climate disclosure. During the two years of waiting for the SEC to finalize their rule, the rest of the world moved ahead with more stringent requirements. Companies should review the interaction of the SEC's new climate- related rules on the disclosures required by other regulators, including certain U.S. states (for example, California) and non-U.S. jurisdictions (for example, the European Union). Areas of potential concern may include potentially duplicative or inconsistent regulatory reporting and/or public disclosure requirements and different protocols or frameworks that apply to these requirements. While the SEC did not provide much guidance on equivalency with other similar requirements, they did reference both the CSRD and California's climate bills, how many companies will be covered by both the SEC rules and these other rules (~3,700 and ~2,520, respectively). Many multinational U.S.-based companies operate in the EU, which will subject them to rules even more stringent than those proposed by the SEC (CSRD and ESRS). The SEC concluded that complying with these other rules would provide affected companies with systems and processes to comply with the SEC rule CALIFORNIA SB 253 California's rule mandates that any company generating annual revenue of over $1 billion that does business in the state measure and publicly report Scope 1 and 2 greenhouse gas emissions starting in 2026, and begin disclosing Scope 3 emissions starting in 2027. It is important for covered entities, as well as those that may see extraterritorial effects of the ruling, to know that SB 253 sweeps more broadly in scope than the SEC proposal in some significant respects. While the SEC has officially voted and approved the enactment of a revised version of the climate rule, which notably drops any requirements for Scope 3, large firms for which this would have applied will still have to contend with Scope 3 for the California rules and EU requirements. The size of California's economy means that its state-level Scope 3 disclosure requirements are likely to cover many of the same companies as the SEC rule. EUROPEAN UNION'S CSRD Under the European Union's Corporate Sustainability Reporting Directive, all organizations listed in an EU-regulated market with 500 or more employees must start reporting in 2025 with data for the 2024 financial year. Other large companies will be required to do the same in subsequent years, followed by small and midsize enterprises. Under the ESRS, companies are required to disclose material environmental, social, and governance impacts and risks within their upstream and downstream value chains – for example, Scope 1, 2, and 3 emissions as well as total greenhouse gas emissions. Sustainability & Energy Management Simplified

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