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EPA Plans to “Driv[e] a Dagger Straight Into the Heart of the Climate Change Religion”
New EPA Administrator Lee Zeldin yesterday issued a shocking announcement touting the “greatest and most consequential day of deregulation in U.S. history” intended to “unleash American energy, lower cost [sic] of living for Americans, [and] revitalize the American auto industry.”...

How To Update Your Company’s Climate Assumptions
This week’s blogs make it clear – companies need to take a hard look at their climate programs and the bases for them. Or, as Advisory Board Member Mark Trexler has said, “audit your climate assumptions.” Mark wrote a pair...

New This Week on PracticalESG.com
This week’s notable additions to PracticalESG.com are below. New Q&A: How Does the Glass Lewis ESG Rating Affect My Company? We have now posted over 120 CSRD reports, which can be viewed here. Blog(s) of the Week: It was a...

Apple Faces Greenwashing Lawsuit Over Offsetting
Apple is known for having a robust sustainability program and making serious sustainability claims. Back in 2023, we wrote about a flashy Apple ad that touted sustainability at the company. I predicted that this may land the company in legal...

Could US Forestry-Based Carbon Offset Projects Soon Be Voided?
A pair of Executive Orders from the new administration could bring down many forestry-based carbon offset projects in the US, creating a tangle of legal, contractual, investor and disclosure risks for many US companies. On March 1, 2025, the President...

US Scope 2 Emissions Reductions May Slow
A developing plan from the new administration would threaten Scope 2 emissions reduction plans. According to Bloomberg, Energy Secretary Chris Wright said last week “The Trump administration is working on a ‘market-based’ plan to stem the closure of US coal-fired...

Executive Order Could Have Major Impacts on GHG Regulation
The scope of the EPA’s power to regulate greenhouse gas emissions under the Clean Air Act (CAA) has been hotly debated in politics for years. This question was the underlying contention in West Virginia v. EPA, where the Supreme Court...

The First CSRD Report Analyses – Good and Bad
Now that final CSRD reports are rolling in, experts are analyzing them every whichaway. Some of the analyses are good, such as this one from Datamaran. My favorite points from Datamaran are: “The survey reveals that companies see the identification...

Is Climate Work Becoming a Crime?
I did not see this coming. According to a report from Politico, “The Trump administration has directed nonprofits involved in a $20 billion Biden-era climate initiative to turn over records to the FBI and appear in federal court later this...

Clarifying Omnibus Part 3: Non-EU Reporting
In the flood of articles, posts and alerts about the recent Omnibus proposal, changes in non-EU reporting obligations have been lost in the shuffle. The CSRD calls for enterprise-wide level reporting for certain companies with a large presence in the...

The Climate Death Match – US Policy v. Business Fundamentals
There probably wasn’t much doubt about what the next four years of US federal climate policy is going to look like – but if there was, this article from The Hill should put it to bed: “Energy Secretary Chris Wright...

New This Week on PracticalESG.com
This week’s notable additions to PracticalESG.com are below. Blog of the Week: Omnibus Scales Back CSRD, Keeps Double Materiality Hot Topics for the Week: “Quantifying The Social Risk Implications Of U.S. Policy Changes”, LION-S (3/25) Multi-State Guidance Concerning Diversity, Equity,...

How To Defend Against Cutbacks to Company Sustainability Programs
No doubt, there’s never been a crazier time to be in sustainability/ESG/CSR. The turmoil and rate of change are unprecedented. And it’s a global phenomenon. This isn’t necessarily great news for ESG/sustainability professionals who must keep track of regulatory/policy changes...

Clarifying Omnibus Part 2: ESRS Changes
Another in a short series on misconceptions I’ve seen regarding the recent EU Omnibus proposal. Many have stated that “Omnibus doesn’t change the ESRS.” While technically correct, the Omnibus proposal does signal major changes coming to the ESRS in the...

Standard Chartered: Scope 2 Reduction Goals Unlikely
The ability for companies to meet Scope 2 reduction targets and goals is increasingly challenging due to macro developments outside the companies’ control. Although wind and solar power generation are at all time highs – and the growth continues –...

Clarifying Omnibus Part 1: Wave 1 CSRD is Not Delayed
The EU’s Omnibus proposal has shaken up the sustainability world and there’s no shortage of opinions and interpretations floating around. Across the coverage and commentary I’ve seen, a common refrain emerges: “CSRD reporting is delayed by two years.” This is...

An Overview of the EU Omnibus’ Drastic Proposed Changes CSDDD
The EU has published its highly anticipated Omnibus proposal. Last week, we discussed the proposed changes to the Corporate Sustainability Reporting Directive (CSRD). The proposal also stands to fundamentally change the Corporate Sustainability Due Diligence Directive (CSDDD). Major changes include...

How To Make Sense of Pricing Strategies for Sustainability
Over the decades, I’ve seen two main approaches to pricing products with regard to sustainability: Premium pricing (a “greenium”) that effectively considers sustainability attributes a luxury factor justifying higher price tags than comparable “standard” products. Sometimes this reflects customer trends/demands...

Omnibus Scales Back CSRD, Keeps Double Materiality
The highly anticipated Omnibus proposal is finally here! While the Corporate Sustainability Reporting Directive (CSRD) is fundamentally altered, the most drastic rumors failed to materialize. Here’s a summary of the main changes proposed for the CSRD: Mandatory CSRD reporting will...

US Institutional Shareholder Support for ESG/Climate Proposals Plummets
If you look to institutional investor action on sustainability/ESG/climate proposals as an indicator of risk or value to your company, you may want to re-calibrate. Net Zero Investor reported: “Shareholder support for ESG and climate resolutions has dropped to a...

New This Week on PracticalESG.com
This week’s notable additions to PracticalESG.com are below. Blog of the Week: Why You Shouldn’t Worry About the CSRD Leaks Hot Topics for the Week: Commission Simplifies Rules On Sustainability And EU Investments, Delivering Over €6 Billion In Administrative Relief...

Trash Talking Chinese Labor Practices May Land You in UK, US Courts
Working conditions and labor practices in Chinese factories have long been targets of rather public Western derision – deservedly so in many cases. But now those criticisms are ending up in US and UK courts as Chinese companies fight back. ...

Survey: 75% of Executives Know AI Conflicts With Sustainability Goals
A new survey of 2,300 global executives published by IT services firm NTT Data provides interesting insights into how C-suites are balancing adoption of AI and corporate sustainability goals. The study addresses questions of balancing innovation and responsibility in terms...

The $30 ESG Report? Don’t Fall for Cheap Sustainability Freelance Work
It’s difficult to figure out what to say about this. The new Trellis/Weinreb Group The State of the Sustainability Profession 2024 report discusses freelance sustainability jobs and projects posted on Upwork. Curiosity got to me and I looked around the...

Why You Shouldn’t Worry About the CSRD Leaks
This weekend, reports flooded in about documents leaked from the European Commission about the Omnibus changes to the CSRD, CSDDD and CBAM. Analyses of the leaked documents inundated my inbox and LinkedIn. But I have a different perspective. They may...

Federal Anti-DEI Efforts Hit Court Roadblock
The new administration has made efforts to rid the federal government of DEI programs a top priority. However, two Anti-DEI Executive Orders facing legal challenges have been partially enjoined by a Maryland District Court. Gibson Dunn covers the specifics of...

First Solar Gives Us Much Needed Good News
It’s been a little challenging to find pockets of sunshine in the sustainability world in the past year or so, but here is something worth celebrating. Net Zero Investor reports that “First Solar is the first solar manufacturer to commit...

New York Climate “Superfund” Law Challenged by Attorneys General
Last December, New York passed a polluter pays “superfund” type law targeting fossil fuels companies. Under the law, fossil fuels companies face strict liability for GHG emissions and would pay into a $75 billion climate resilience fund. This fund would...

NBIM: ESG/Sustainability-Related Divestment Doesn’t Really Work
I’ve long questioned the belief that divestment is an effective strategy for incentivizing company change. If one investor sells a company’s stock, someone on the other end buys it at market value. Granted, if the investor is big enough or...

New This Week on PracticalESG.com
This week’s notable additions to PracticalESG.com are below. Blog of the Week: Legal Departments See Big Changes Related to Sustainability Staffing Hot Topics for the Week: “Voting Matters 2024: Are Asset Managers Using Their Proxy Votes For Action On Environmental...

PCAOB: Environmental/Climate Subject Matter Specialists Create Audit Risks
In the US, the Public Company Accounting Oversight Board (PCAOB) released a new document Spotlight: Considerations for Audit Firms Using the Work of Specialists. As the scope of accounting and financial disclosures has evolved, the need for specialized knowledge has...

Shifts in Corporate Sustainability Functions (Part 2)
Last week, I blogged about how sustainability staffing has transformed according to the recent Trellis/Weinreb Group report The State of the Sustainability Profession 2024. Today, let’s look at some of the changes in corporate culture impacting ESG/sustainability. We’ll start with...

UK Judge Halts Shell Project Approval Over Scope 3
Back in June of 2024, a decision from the UK Supreme Court held that oil and gas developers must include scope 3 emissions in their Environmental Impact Assessments (EIA). Now Shell is feeling the consequences of the ruling as the...

New SEC Guidance Impacts Shareholder Input to Double Materiality Assessments
Marc Rotter at Ropes & Gray recently issued a client note about an update to SEC’s “guidance on circumstances in which investors engaging with issuers on ESG and other matters can file a short-form Schedule 13G [for certain investors with...

Rethinking Sustainability ROI
Last week, Lawrence wrote about the new (or old, depending on your perspective) emphasis on the sustainability business case. Over the past month, we’ve seen seismic shifts in the ESG world, largely driven by political developments in the US and...

Let’s Talk About Communicating
Near the end of last week’s GreebBiz 25 conference, the Trellis Briefing included four themes Richard Martin thought summed up the conference. These are in addition to the theme of business realities I wrote about last week. One theme he...

Legal Departments See Big Changes Related to Sustainability Staffing
The new Trellis/Weinreb Group report The State of the Sustainability Profession 2024 has some very good insights about what is happening with corporate sustainability programs, leadership and staffing. Here are a few tidbits from the report: At least as of...

The New Future of Sustainability Is … Its Past
It’s Back to the Future for sustainability, but without the DeLorean or hoverboard skateboard. When sustainability first became a real thing in the 1990s, those of us in the space came from environmental backgrounds, working to elevate sustainability as financially...

New This Week on PracticalESG.com
This week’s notable additions to PracticalESG.com are below. Blog of the Week: We had a big surge in blog readership this past week but the most popular was The Wheels on the (Omni)Bus Go Round and Round. Hot Topics for...
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Featured Q&A Members Only
Glass Lewis ESG Profile
In reading my company’s Glass Lewis report from last year, they indicated that my company’s risk profile is “Medium”. Considering this rating didn’t affect GL’s recommendations to our proposals, how else does this affect my company? Is the rating meant to give a reader a second thought on voting by following GL’s (positive) recommendation on our proposals? Is it meant to generally shame us? ESG newbie here.
03/6/2025, Question #27139
GHG Emissions “Restatements” Under CSRD and SEC
Assume a company considers GHG emissions or another ESG matter as material and they treat it as such in their SEC 10-K/20-F. Primarily this is reflected in the MD&A and Risk Factors Disclosures, but it may also include financials related to emissions trading (especially for companies that have significant trading transactions).
If the company publishes a sustainability-related “restatement” (for GHG data from previous years) under the new CSRD regime in the EU, would that impact SEC filings? Is any type of restatement triggered for SEC?
Here is a link to an example of a discussion about an emissions “restatement” in CSRD reporting: https://www.linkedin.com/posts/maximuel_lets-talk-about-emission-restatements-novo-activity-7292888302393708544-3zsM
02/5/2025, Question #26673
Non-GAAP Measure in ESG Report?
Would Reg G apply to a non-GAAP measure included in a public company’s ESG Report posted on its website? Assume that’s the case but wanted to get thoughts given it is not so common.
02/4/2025, Question #26618