ESG

Climate Disclosure Countdown: Preparing Your Energy Data for Compliance

New global climate disclosure rules are changing how large enterprises and commercial real estate portfolios need to manage their energy data. Regulations like the EU’s Corporate Sustainability Reporting Directive (CSRD), California’s Senate Bill 253 (SB 253), and the IFRS Sustainability Disclosure Standards (IFRS S2) all require detailed, verifiable emissions reporting. For many organizations, this means building a stronger foundation for how energy data is collected, managed, and reported, a task that often involves stakeholders who cut across regions and departmental lines.

In this post, we’ll explore how companies can prepare their energy data infrastructure to meet the growing demands of climate disclosures. We’ll break down each major regulation, outline the best practices for energy data management, and offer practical steps to move from compliance chaos to confidence.

Why Energy Data Is at the Heart of Climate Compliance

Energy data has long been used to manage costs and operations, but it’s now also essential for regulatory reporting. Each of the new frameworks puts a spotlight on GHG emissions, especially Scope 1 (direct emissions), Scope 2 (from purchased energy), and, in many cases, Scope 3 (supply chain and indirect emissions).

To meet these standards, organizations need structured, verifiable data from across their assets, whether that’s a global office footprint, owned and/or leased buildings, or upstream suppliers. The complexity is compounded by fragmented data systems, regional variation, and increasing audit requirements.

What ties everything together is the need for accurate, traceable, and timely energy data. That includes everything from utility bills and smart meters to building management system data and fuel records. The challenge is getting that data into a usable format for disclosures that have different timelines, scopes, and technical requirements.

The Regulatory Landscape: CSRD, SB 253, and IFRS S2

CSRD (Corporate Sustainability Reporting Directive) – EU

Who it affects: All large EU companies, as well as non-EU companies with significant EU operations (net turnover of €150 million in the EU).
Key requirements: Double materiality, third-party assurance, and granular emissions reporting.
Reporting timeline: Starts in 2025 for companies already subject to the EU’s Non-Financial Reporting Directive (NFRD), covering FY2024. Expands in 2026 and 2027 to include other large EU and non-EU companies.
Energy data implications: Mandatory Scope 1, 2, and material Scope 3 disclosure tied to actual consumption data—not estimates. Emphasizes transparency across value chains.

SB 253 (California Climate Corporate Data Accountability Act)

Who it affects: Public and private companies doing business in California with annual revenues over $1 billion.
Key requirements: Mandatory reporting of Scope 1 and 2 emissions starting in 2026, and Scope 3 in 2027. Requires third-party assurance and digital platform submissions.
Reporting timeline: Scope 1 and 2 emissions disclosures begin in 2026 (covering FY2025). Scope 3 emissions disclosures required starting in 2027 (covering FY2026).
Energy data implications: High pressure on organizations to trace energy consumption across their operations and upstream/downstream activities.

IFRS S2 (International Financial Reporting Standards for Climate-Related Disclosures)

Who it affects: Companies operating in jurisdictions adopting ISSB standards (including Canada, UK, Australia, Singapore, and more).
Key requirements: Disclosure of climate-related risks, Scope 1–3 GHG emissions, transition planning, and energy-related financial metrics.
Reporting timeline: Effective January 2024; local adoption and mandatory timelines vary by jurisdiction. Early voluntary adoption is already underway in some markets.
Energy data implications: Demands integrated reporting between sustainability and finance teams, with auditable energy usage data supporting climate risk disclosures.

Despite jurisdictional differences, these standards all require consistency, defensibility, and integration of energy data across corporate functions.

Best Practices: Getting Your Energy Data Compliance-Ready

For large enterprises and commercial real estate portfolios, energy data often exists across a patchwork of systems, formats, departments, and locations. The first step toward readiness is to centralize that data into a unified platform. This means consolidating inputs from utility bills, interval and real-time meters, building management systems, and renewable energy agreements. In portfolios with tenant submetering or diverse ownership structures, the ability to normalize and standardize data across properties becomes especially critical. A centralized approach improves visibility, consistency, and – ultimately – the ability to report with confidence.

Alongside centralization, organizations must apply consistent methodologies for emissions calculations. Regulators expect disclosures to follow established frameworks like the Greenhouse Gas Protocol and to use emissions factors that are regionally appropriate, such as those provided by the EPA, IEA, or DEFRA. It’s also important to distinguish between location-based and market-based Scope 2 emissions, especially in markets with renewable energy sourcing. Automating these calculations within data platforms (like Noda) can help reduce manual workload and ensure consistency across reports and time periods.

Clear boundary definitions are another key step. For enterprise-scale reporting, understanding which entities and facilities fall under operational or financial control is essential for accurate Scope 1 and 2 disclosures. Mapping the full scope of emissions sources – by jurisdiction, business unit, or ownership model – makes it easier to allocate emissions appropriately and align with regional regulatory expectations. The more granular this mapping, the more defensible and actionable the resulting disclosures will be.

Finally, organizations should treat energy data with the same rigor as financial data. That means maintaining a robust audit trail that tracks where each data point originated, who modified it, and when. Data lineage, version control, and approvals are no longer optional, but are rather core to meeting third-party assurance requirements. At the same time, energy data should not live in a silo. With growing links between emissions, financial exposure, and brand reputation, this information needs to flow across risk, finance, ESG, and operations teams. By building these connections early, companies can ensure that energy data supports not just compliance, but better business decisions in the long run.

Three-Phase Action Plan for Large Enterprises

Preparing energy data for climate disclosure doesn’t need to be overwhelming. Many organizations will in fact benefit from approaching it in phases. The first step is to assess and inventory all existing energy data across the portfolio. This means identifying every source of consumption data, from utility bills and fuel purchases to on-site metering and BMS systems. It’s also important to evaluate the quality and accessibility of this data – understanding where it's stored (e.g. spreadsheets, PDFs, databases) and where there may be gaps. Mapping these findings against relevant regulatory obligations by geography and entity can help establish a clear path forward.

Next comes automation and standardization. At this stage, organizations should consider implementing a scalable energy data platform (like Noda) that can centralize inputs, automate data capture, and apply consistent methodologies for emissions calculations. This ensures energy and emissions data are accurate, traceable, and structured in a way that aligns with evolving frameworks (as well as any internal or investor reporting requirements).

Finally, in the reporting and optimization phase, companies should generate outputs that meet disclosure mandates while also supporting internal decision-making. Internal dashboards can help monitor emissions at both the building/asset and enterprise level, enabling ESG, legal, finance, and real estate teams to collaborate more effectively. These insights also serve as a foundation for evaluating decarbonization opportunities, scenario planning, and long-term capital investment strategies.

Putting it All Together: Your Step-by-Step Action Plan for Data Readiness

Phase 1: Assess and Inventory

Identify all sources of energy data (utility, meters, fuel)
Inventory where and how data is stored (PDFs, databases, spreadsheets)
Evaluate gaps in data coverage or quality
Map your regulatory obligations by jurisdiction

Phase 2: Automate and Standardize

Implement an energy data platform or shared system of record
Automate utility data capture where possible
Apply consistent methodologies and emissions factors
Normalize data for easy export to reporting frameworks

Phase 3: Report and Optimize

Align data outputs with CSRD, SB 253, and IFRS S2 requirements
Build internal dashboards for GHG performance
Share outputs with legal, finance, and ESG teams
Use insights to inform decarbonization and transition strategies

Looking Ahead

For commercial real estate operators and global enterprises, the shift toward mandatory climate disclosure is accelerating. But with the right foundation in place, regulatory compliance can serve as more than just a reporting exercise. A structured approach to energy data not only reduces risk, but also enables organizations to unlock deeper insights about performance, build investor and stakeholder trust, and make more confident, data-driven decisions. Aligning compliance efforts with broader operational and financial strategies can turn energy data into a strategic asset – and position companies for long-term resilience in a rapidly evolving regulatory landscape.

About Noda

Noda is a data and analytics company on a mission to make every building smarter, more efficient, and more sustainable. Recently ranked in the top 10 tech companies leading the charge on climate action, its AI-powered suite of products surface unique insights that empower real estate teams to reduce costs, decrease time spent on routine work, and find and act on opportunities to save energy and carbon. Discover how Noda's solutions can unlock the potential of your assets and accelerate the transition to net zero. Visit us at noda.ai to learn more.