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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 Though these bills focus on US companies that do business in California, they are part of a global movement towards legislation requiring robust climate reporting from companies, including the SEC's proposed climate disclosure rule in the US and the Corporate Sustainability Reporting Directive (CSRD) in the EU. Sustainability & Energy Management Simplified SEC CLIMATE DISCLOSURE RULE 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. Where the SEC sweeps broader is in the qualitative risk statements. While California's SB 261 also covers material risk disclosure, the SEC rules require additional disclosures of climate-related governance, strategy, and transition plans. EU 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. Public and Private Companies: SB 261 and SB 253 apply to partnerships, private corporations, and limited liability companies. In contrast, the proposed SEC rule only applies to publicly listed or traded companies. Scope 3 Emissions: SB 253 requires disclosure of all Scope 1, 2, and 3 emissions. The proposed SEC rule does not require disclosure of Scope 3 emissions and Scope 1 and 2 only if material. ISSB In 2023, the International Financial Reporting Standards (IFRS) issued IFRS S2 Climate-related Disclosures, which require companies to disclose absolute gross GHG emissions generated during the reporting period, measured following the GHG Protocol, including Scope 1, 2, and 3 GHG emissions. It is up to individual jurisdictions worldwide to adopt and/or adapt the standards issued by the ISSB, however, many G20 countries have signaled their support. Sustainability & Energy Management Simplified

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