Rethinking Your Company’s Approach to ESG Disclosures
Brooke Dillon
September 26, 2025
The combination of these factors, coupled with the challenges of ESG data collection and an increase in greenwashing scrutiny and litigation, have led many organizations to slow down and rethink their approach to disclosure.
How Companies are Adapting
Reporting entities are facing a number of reporting-related challenges, including the complexity and fragmentation of the ESG regulatory landscape, data quality and accuracy, the risk of greenwashing, and meeting the needs of a diverse stakeholder base.
Successful companies are adapting to the current environment by defining a strategy focused on the organization’s specific areas of risk and impact that is also aligned to the overarching business strategy. They are also developing appropriate governance structures and processes to ensure that there is accountability across the organization for ESG data collection and reporting. A well-developed strategy can then guide the company’s approach to disclosure – selecting the appropriate reporting framework, building right-sized data systems, engaging the necessary stakeholders, and establishing a system of continuous improvement.
How to be Prepared
First, companies need to understand how and when current and emerging regulatory requirements apply to their operations and which ESG topic areas are non-negotiable or “must disclose” issues with their stakeholders. In 2025, we are still seeing some smaller firms without standardized processes for GHG emissions data collection and management or with GHG data that is not audit-ready. Auditable Scope 1 and 2 GHG emission data should be a bare minimum for most organizations.
Additionally, the current disclosure environment demands that companies have a detailed understanding of their impacts to communities and the environment, and the expectations of their stakeholders/investors around these impacts. We’ve found the double materiality assessment process (required by the EU CSR) to be an invaluable tool, providing company leadership with direction on how best to allocate resources for the greatest impact and financial success.
Once critical ESG topic areas are identified, procedures and policies around data collection, governance, and disclosure can be established. Stakeholder demands will continue to be present and evolve, even if the regulatory environment keeps changing.
Looking Ahead
I expect that we’ll see continued variation in the comprehensiveness of ESG disclosures as organizations try to navigate through the somewhat murky guidelines provided with the California Climate-Related Financial Risk Act (SB 261) and the California Climate Corporate Data Accountability Act.
We may find that early adopters of voluntary reporting frameworks will disclose less information than they have in years past, focused on strict regulatory compliance, and that new reporters will rush to prepare disclosures that meet the bare minimum requirements knowing some agency leniency is likely.
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About the Author
Brooke Dillon
Ramboll
Brooke Dillon is a versatile environmental and environmental, social and governance (ESG) consultant with 25 years of experience supporting industrial, financial and commercial clients to identify and manage ESG-related risks and opportunities, comply with environmental, health and safety (EHS) regulatory requirements, reduce their environmental impact, and drive continuous improvement. She provides environmental management system and compliance support to corporate and industrial clients. She also works with corporate, financial and legal clients to help them understand ESG risks and opportunities in M&A transactions and implement strategies for value creation post-closure. Brooke also serves as a key account manager for a variety of commercial, industrial and financial clients.
Her academic background includes undergraduate work in chemistry (organic chemistry and biochemistry) and graduate work in environmental regulatory policy, hydrogeology and contaminant fate and transport.
Her academic background includes undergraduate work in chemistry (organic chemistry and biochemistry) and graduate work in environmental regulatory policy, hydrogeology and contaminant fate and transport.