Document Type

Report

Publication Date

9-2025

Abstract

In recent years, roughly 30 nations have implemented regulatory regimes that mandate some type of greenhouse gas (GHG) emissions disclosure from corporations. As GHG emissions disclosure regimes continue to take hold, several key questions arise: will they prompt meaningful and sustained reductions, or will they merely serve to document corporations’ unabated emissions? And if these regimes do lead to lasting emissions reductions, precisely what causes the changes in companies’ behavior? These questions are particularly relevant as climate advocates grapple with the merits of disclosure as a tool for real emissions impact, and as policymakers refine disclosure requirements to best fit their range of environmental and investor protection goals.

This paper reviews the academic literature evaluating mandatory and voluntary GHG emissions disclosure regimes, and analyses key theories of impact, synthesizing the classic “you manage what you measure” justification of corporate disclosure with prevailing social-science models of effective regimes. First, the paper outlines this contemporary theoretical framework for effective “double-embedded” disclosure regimes that depend on feedback loops to drive change, as articulated in landmark publications by Weil, Fung, Graham & Fagotto (2006) and Weil, Graham & Fung (2013). Second, the paper evaluates mandatory and voluntary disclosure regimes’ measured effects on corporate GHG emissions. Because relatively little research has been published on corporate behavioral responses to GHG emissions disclosures, the report also considers case studies of analogous disclosure programs, including the Environmental Protection Agency’s (EPA) Toxic Release Inventory and the Securities and Exchange Commission’s (SEC) executive compensation disclosure regimes. Third, the paper evaluates evidence of causal mechanisms by which reported emissions data can lead to actual emissions reductions. Finally, the paper outlines a research agenda for expanding the empirical evidence on disclosure regimes’ behavioral impacts in the current regulatory environment.

Disciplines

Banking and Finance Law | Environmental Law | Law

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