Climate policy in 2026 is moving in multiple directions at once. The US is stepping back at the federal level while California and New York advance independently. Europe has adopted a binding 2040 emissions target and simplified the scope of corporate sustainability reporting. The UK has published ISSB-aligned sustainability standards and is moving toward mandatory adoption.
Despite this divergence, the direction is clear: climate disclosure obligations are tightening, and supply chain emissions (particularly Scope 3 freight transportation) are at the center of what regulators are asking companies to measure, report and defend.
For companies operating across regions, emissions are no longer just a reporting output. They are becoming a regulated, auditable, and financially consequential variable tied directly to supply chain operations.
What changed in climate disclosure rules in 2026?
Europe: Binding targets, narrower scope, and real carbon costs
What does the EU 2040 emissions target mean for supply chains?
In March 5, 2026, the European Parliament adopted an amended EU Climate Law, setting a binding 90% net emissions reduction target by 2040 (vs 1990 levels). The framework includes:
- Biennial review mechanisms
- Use of high-quality international carbon credits (up to 5% from 2036)
For supply chain leaders, the importance is structural: This target sets the policy floor for all downstream regulations through 2040.
A company optimizing for today’s requirements is optimizing against a trajectory that will continue to tighten.
Who still needs to comply with CSRD after the Omnibus update?
The Omnibus I simplification package narrows the scope of CSDDD and CSRD. For Corporate Sustainability Reporting Directive (CSRD), particularly, the revised thresholds apply to:
- Companies with >1,000 employees and >€450M turnover
- Non-EU companies generating >€450M in the EU
- Subsidiaries/branches above €200M
It also introduces a transition exemption for early reporters (2025–2026).
However, the Omnibus changed who must report, not the quality of data required.
For companies still in scope, particularly large multinationals, Scope 3 disclosure expectations remain unchanged.
How does EU ETS affect freight costs?
The EU Emissions Trading System (ETS) is already translating emissions into direct logistics costs.
From 2026:
- 100% of emissions from intra-EU voyages are covered
- 50% of emissions on inbound/outbound voyages apply
- Carbon costs are rising (projected up to €122/ton by 2030)
The scale is significant:
- 22.9% of container voyages affected in 2025
- ~26.9 million tons of emissions covered in 2026
- >€2 billion annual cost to carriers, passed to shippers via surcharges
Carriers are responsible for emissions reporting and recovering costs through:
- Flat fee surcharges
- Trade and container-specific pricing models (like Maersk)
Carbon is now a line item on freight invoices.
(For a detailed breakdown, see our previous analysis: EU ETS: The €2 Billion Carbon Bill for Global Container Shipping.)
How does the EU ETS create a mismatch between cost and reported emissions?
The mechanism that connects EU ETS to shippers is surcharges. Carriers are legally responsible for monitoring, reporting and verifying their emissions data. They recover compliance costs by adding ETS surcharges to freight contracts, reassessed quarterly. For Q1 2026, Maersk's surcharge table differentiates by trade, container size and container type. Other carriers apply flat or simplified surcharge structures. The result is that the vessel's actual emissions on a specific voyage determine a cost that lands on the shipper's freight bill.
This is where the data quality problem becomes a financial problem. The EU ETS surcharge applied to your freight is based on the vessel's actual voyage emissions. But most shippers calculate and report their own Scope 3 Category 4 emissions using historical data, averages and/or carrier-provided spreadsheets built on minimum feasible distances and assumed load factors. Those calculations do not reflect what the vessel actually emitted. The difference between the average and the actual can represent tens of thousands of euros per year in misallocated cost, and a Scope 3 number that does not correspond to what you were billed for.
What is EU ETS2 and how is it different?
EU ETS 2 is a separate cap-and-trade system targeting greenhouse gas emissions from fuel combustion in road transport, buildings and small industry. It is not an extension of the maritime ETS. Following the December 2025 agreement, its start date has been postponed by one year, from 2027 to 2028. EU ETS 2 is relevant to companies with large road transport footprints in Europe, as it will add a carbon cost dimension to road haulage, but its mechanics and scope are distinct from the maritime ETS discussed above.
UK: What does SRS S2 require and why does it matter?
The UK has published SRS S1 and SRS S2, aligned with ISSB standards, with mandatory adoption under consultation for 2027.
SRS S2 requires disclosure of:
- Scope 1
- Scope 2
- Scope 3 emissions
For companies with significant freight supply chains, Scope 3 Category 4 (upstream transportation and distribution ) is often one of the largest single contributors to total reported emissions in any climate disclosure, and structurally one of the most complex to measure accurately.
What data hierarchy does SRS S2 require?
Appendix B (B40–B54) establishes a strict measurement hierarchy. Entities must prioritize:
- Data based on direct measurement
- Data from specific activities within the entity's value chain (primary data)
- Timely data that faithfully represents the jurisdiction and technology used in the value chain activity during the reporting period
- Verified data
The standard is explicit: Primary data is more representative and must be prioritized over secondary data.
On timeliness: Data must reflect the actual technology, geography, and activity during the reporting period.
Why is this a problem? Most companies reporting Scope 3 emissions today rely on secondary data: industry-average emission factors, carrier-provided estimates, or framework-based calculations that are not specific to the shipments, routes, vessels, that actually moved their freight. Under SRS S2, companies must explain and justify their methodology and demonstrate that it reflects actual activity.
This is a significantly higher bar than simply producing a number.
Does this apply beyond ocean freight?
Yes. The same data quality framework applies across all modes:
- Road freight → truck-level dat with load factors and fuel consumption
- Air freight → flight-level activity data
- Ocean freight → vessel-level emissions
A multimodal emissions strategy built on aggregate data is unlikely to meet SRS S2 requirements.
What are the risks of inaccurate Scope 3 reporting?
The UK Competition and Markets Authority (CMA) updated its Green Claims Guidance, clarifying:
- Companies may be liable for misleading environmental claims
- Liability extends into the value chain
This shifts emissions reporting into a risk domain: If your Scope 3 data is materially wrong, it is no longer just a measurement issue; it is a disclosure risk with legal & financial exposure attached.
US: The Effective Environment Is More Demanding Than It Looks
What is happening at the federal level?
The current US federal administration has repealed the EPA's 2009 Greenhouse Gas Endangerment Finding, removing the legal foundation for federal carbon regulation. The SEC has delayed compliance with its Names Rule amendments to 2027 and 2028. At the federal level, the direction is clearly toward less mandatory disclosure, not more.
For any company operating at scale in California or New York, the federal picture is largely irrelevant because state-level regulation is accelerating.
California SB 253: Already in the first reporting cycle
California’s Climate Corporate Data Accountability Act (SB 253):
- Applies to companies with >$1B revenue
- Covers Scope 1, 2, and 3 emissions
- ~5,400 companies in scope
Timeline:
- Scope 1 & 2 reporting began in 2026 (FY2025 data)
- Scope 3 begins in 2027 (FY2026 data)
Additional elements:
- Safe harbor provision for Scope 3 disclosures made with a reasonable basis and disclosed in good faith until 2030
- Third-party assurance scaling over time
CARB is expected to issue a second rulemaking in 2026 addressing details about 2027 reporting and beyond, which will provide further clarity on data quality expectations and assurance requirements for future years.
What is happening in New York?
New York has two parallel GHG reporting frameworks:
1. Facility-level reporting Mandatory Greenhouse Gas Reporting Program (6 NYCRR Part 253)
- Applies to facilities emitting >10,000 metric tons CO2e
- Starts 2026 (reporting due 2027)
- Verification required above 25,000 tons
2. Climate Corporate Data Accountability Act (Senate Bill S3456)
- Applies to companies >$1B revenue
- Requires Scope 1, 2, 3 disclosure
- Third-party verification required
- Public reporting via centralized platform
CCDApassed the New York Senate on February 10, 2026 by 40 votes to 22 and has moved to the Assembly. This is a corporate-level disclosure law, not a facility-level one. It targets US-based public and private companies that do business in New York.
For companies operating in California and New York, compliance is driven by state law, not federal policy.
Why Climate Disclosure Is Now an Operational Challenge for Supply Chain Emissions
Across regions, mechanisms differ:
- EU → regulation + carbon pricing
- UK → strict data hierarchy
- US → mandatory disclosure (state level)
But the direction converges: Scope 3 emissions are no longer estimates. They are regulated disclosures subject to audit, verification, and financial consequences.
For companies with significant freight transport, this shift exposes a deeper problem that predates the regulation. Most Scope 3 emissions scorecards are rear-view mirrors. They tell companies what happened, in aggregate, based on data that is months old by the time it is applied. They rarely generate the insights needed to decide which carrier to select which schedule change reduces both cost and carbon, or where structural emissions reductions are actually achievable. The frameworks that now require higher quality Scope 3 disclosure, particularly UK SRS S2 and CSRD, are clear that primary, activity-specific and timely data must take precedence over secondary averages. The EU ETS reinforces this in financial terms: a carbon cost calculated on a trade-lane average does not reflect the actual emissions derived from the vessel’s performance during the voyage.
Decarbonisation is not the same as reporting; it is an operational challenge. It requires granular, real-time data to change operational decisions, not just document what has already happened.
At VesselBot, we built our Supply Chain Sustainability platform to solve this problem: turning fragmented, average-based emissions estimates into execution-grade data that reflects what actually happened, shipment by shipment, across ocean, road, air, and last mile, and translating that into the operational intelligence needed to decarbonize at the level where emissions are actually generated. The regulatory developments above do not change that mission. They make it more urgent.