In the lead-up to COP30 in Brazil, the newly created Task Force for Corporate Action Transparency (TCAT) launched two comprehensive greenhouse gas reporting frameworks designed to fill an important gap in how companies measure, report on, and verify their corporate climate actions.  TCAT leadership has indicated that the frameworks will be formally launched at COP30 in Belém, Brazil, this week highlighting their expected role in shaping global climate action discourse.

The new guidance documents—developed through a collaboration among environmental groups, accounting experts, NGOs, business practitioners, and civil society members—are designed to help companies explain exactly how they are lowering their emissions in real time, in a way that is comparable across industries and verifiable by third parties.  This effort reflects the increasing sophistication and rising expectations surrounding corporate climate actions.  In the United States, particularly in the absence of more active federal governmental emissions reduction activities, those private sector actions are likely to take on increasing importance and be subject to even greater scrutiny.  The TCAT effort can bolster the credibility of business emissions reduction efforts.

Until now, companies have been able to report numerical emissions data through frameworks like the Greenhouse Gas Protocol (“GHGP”) or set reduction targets through initiatives like the Science Based Targets initiative (“SBTi”).  A company might disclose that it cut emissions by 30% compared with the previous year, or by a certain number of million metric tons.  Yet existing frameworks have lacked standardized methods for companies to report the specific actions (i.e., labeled by the TCAT as “GHG-related activities”) behind those reductions: whether transport companies are replacing diesel trucks with electric vehicles, manufacturers are capturing and storing carbon dioxide in underground reservoirs, or a technology firm is purchasing renewable energy certificates for its data centers’ electricity use.

TCAT’s frameworks emerge at a key moment in the evolution of climate disclosures.  While jurisdictions worldwide, including California and the European Union, are on (a winding) course to implement mandatory emissions reporting requirements, significant questions remain about how companies can credibly demonstrate the ways in which they mitigate emissions and the actual impact of their efforts.  TCAT’s guidance is designed to sit alongside these compliance regimes while providing the standardization and detail needed to distinguish genuine climate action from accounting adjustments or business changes independent of climate action—with the goal of enhancing the transparency, comparability, and reliability of reporting on those important efforts.

The Two New Frameworks

Mitigation Action Accounting and Reporting Guidance (MAARG)

The MAARG equips companies with tools to account transparently for the full spectrum of ton-denominated climate actions.  Its multi-statement approach enables companies to report on climate actions without conflating different types of activities.  Consider a technology company that reduces emissions at its data centers (Physical Inventory), purchases renewable energy certificates (Contractual Inventory), quantifies the climate benefits and atmospheric impacts of its reduced data center emissions (Inventory Impact Mitigation Statement), invests in methane reduction technology for its semiconductor suppliers (Sector Impact), and funds cookstove distribution programs in sub-Saharan Africa (Global Impact).  Under traditional reporting, these diverse actions might be aggregated in ways that conceal their distinct nature and actual climate benefits.  MAARG’s framework allows each to be clearly categorized and measured.

Rather than consolidating all GHG-related activities into a single statement, which can obscure the distinction between actual emission reductions and accounting-only or business changes, MAARG introduces a five-statement reporting framework which supports both inventory and impact accounting:

  1. Physical Inventory Statement (Required):  A company’s total emissions, including Scope 1, 2, and 3 emissions, comparable to output from existing GHG inventory accounting standards.
  2. Contractual Inventory Statement (Optional):  A restatement of a company’s Physical Inventory adjusted by reductions and removals from qualified contractual instruments, such as market-based mechanisms like renewable energy certificates (RECs).
  3. Inventory Impact Mitigation Statement (Optional):  A measurement of the impact from mitigation outcomes reported in the first two statements; distinguishing true climate benefits from accounting-only changes by providing visibility into the actual impact of actions companies take to reduce inventory emissions.
    • For example, an apparel manufacturer that switches from conventional cotton (with an emission factor of 2.5 tCO₂e/ton) to low-carbon, regenerative cotton (1.8 tCO₂e/ton) would report the lower emissions in their Physical Inventory Statement.  The Inventory Impact Mitigation Statement would then quantify the actual climate benefit (calculating the actual atmospheric impact):  by procuring 10,000 tons of regenerative cotton instead of conventional cotton, the company achieved a verified emission reduction of 7,000 tCO₂e, calculated as the difference between what emissions would have been (25,000 tCO₂e) versus what actually occurred (18,000 tCO₂e).
  4. Sector Impact Mitigation Statement (Optional):  A measurement of the impact of qualified mitigation outcomes associated with emitting activities in a company’s inventory that were not or cannot be reported in the inventory statements.
    • An example of sector-associated impact is a food and beverage company investing in regenerative grazing practices, though not through a specific, known supplier.
  5. Global Impact Mitigation Statement (Optional):  A measurement of the impact of qualified mitigation outcomes driving global emission reductions and removals beyond a company’s inventory or sector.  For example, investments in forestry projects or renewable energy deployment in emerging markets.
    • Examples of global impacts are paying for a forest planting project to generate carbon removals (despite not having land-use emissions in the company’s value chain) or funding efficiency upgrades on 10 cargo ships through an industry association though the company has no maritime logistics in its operations.

Importantly, MAARG is designed to be neutral with regards to climate target frameworks and does not prescribe how reported outcomes should be used for claims or goal-setting.  The guidance provides two accounting methods supporting reporting across all five statements and explicitly supports both inventory accounting (Statements 1 and 2) and impact accounting (Statements 3, 4, and 5).

Target Accounting and Reporting Guidance (TARG)

TCAT’s second new framework is the TARG which provides structured guidance for setting voluntary climate targets, tracking progress, and communicating results.  For example, a consumer goods company that commits to reducing Scope 1 and 2 emissions by 50% by 2030 would use TARG to document this commitment, establish its 2020 baseline emissions, report annually on mitigation actions taken (such as facility electrification or renewable energy procurement), track cumulative progress toward the 50% reduction goal, and ultimately demonstrate target achievement.  This standardized approach enables stakeholders to assess the credibility and ambition of corporate climate targets and evaluate actual performance against commitments.

In the absence of a unified framework in the voluntary reporting space, TARG fills a critical gap by offering clear and consistent methods for companies to disclose climate targets and report progress in a transparent and assurable manner.  The framework is built around five core reporting elements:

  1. Target Commitment Report:  Documents the company’s climate target with specificity regarding scope, timeframe, and methodological approach.
  2. Base Year Emission Report:  Establishes base year emissions using recognized inventory standards, creating the benchmark against which progress will be measured.
  3. Mitigation Action Report:  Uses a multi-statement reporting template to disclose results of all “GHG-related activities” (i.e., emission reduction activities) implemented over a reporting period.
  4. Target Accounting Report:  Consolidates eligible emissions and mitigation data from previous reports to track progress over time against the established target.
  5. Target Attainment Report:  Summarizes results from the four previous reports and provides documentation that the target has been met.

Of note, companies adopting TARG will want to assess the interplay with their reporting on climate targets under any applicable mandatory frameworks, particularly the EU’s Corporate Sustainability Reporting Directive (CSRD) and the target-specific disclosures in standard E1 of the European Sustainability Reporting Standards (ESRS).  Depending on the outcome of the negotiations regarding the future trajectory and contours of the EU’s Corporate Sustainability Due Diligence Directive (CSDDD), adopting the TARG may also intersect with the mandatory requirements for a climate transition plan.

Corporate Pilot Program and Public Consultation

TCAT is currently facilitating a corporate pilot for both guidance documents during the fall of 2025.  Thirteen diverse companies are piloting the frameworks.  These companies will play a critical role in validating the usability, clarity, and effectiveness of the guidance in real-world applications across diverse business models and sectors.

A second pilot phase will follow in 2026, with a public consultation scheduled for early 2026.  TCAT plans to finalize and publish the second version of the guidance documents by the end of 2026, incorporating feedback from both the pilot programs and public consultation.  The frameworks have already obtained endorsements from several prominent nonprofits with deep expertise in the climate policy and carbon emissions areas.

Interoperability and What This Means for Companies

A key feature of TCAT’s frameworks is their designed interoperability with existing standards and reporting requirements.  For example, companies subject to California’s Climate Corporate Data Accountability Act (SB 253) should be able to use TCAT guidance to supplement mandatory disclosures without creating duplicative reporting burdens, while going beyond basic inventory reporting to demonstrate the impact of mitigation efforts in a standardized and comparable way.  As this type of reporting gains traction, companies should consider several key implications:

  • Enhanced scrutiny of climate claims:  Stakeholders may increasingly expect detailed, third-party assured documentation of mitigation efforts.  Broad claims about “carbon neutrality” or “net zero” without sufficient support are set to face growing scrutiny from private stakeholders and regulatory authorities as the overall sustainability reporting ecosystem matures.  These guiding frameworks could serve to provide appropriate substantiation for these claims.
  • Opportunities for differentiation:  Companies that have invested in emission reductions will have a clearer pathway to demonstrate credibility and distinguish themselves from competitors making less substantive commitments.
  • Integration with existing reporting:  Companies should assess how TCAT frameworks could enhance their current GHG accounting systems and disclosure practices.  For many organizations, adoption would not require complete replacement but rather restructuring how climate data is categorized and presented.

Looking Ahead

TCAT’s launch represents a significant development in the ongoing effort to improve corporate climate accountability.  The initiative’s success will ultimately depend on adoption by companies, acceptance by assurance providers, and demand from stakeholders.

Photo of Gary S. Guzy Gary S. Guzy

Gary Guzy brings thirty five years of experience in environmental law, regulation, and public policy. He provides counsel to industry leaders in the transportation, energy, technology, and consumer sectors on emerging environmental and clean energy issues. He is skilled at creating strategic partnerships…

Gary Guzy brings thirty five years of experience in environmental law, regulation, and public policy. He provides counsel to industry leaders in the transportation, energy, technology, and consumer sectors on emerging environmental and clean energy issues. He is skilled at creating strategic partnerships that bring together diverse groups to resolve challenging public policy controversies through close work with industry and environmental community leaders. Mr. Guzy co-chairs the firm’s Energy Industry Group.

Mr. Guzy served as Deputy Director and General Counsel of the White House Council on Environmental Quality (CEQ). In this position, he helped develop and guide the Obama Administration’s environmental, public health, and clean energy agenda, bringing business insights to government policy and coordinating policy across government agencies. He spearheaded negotiations that achieved the Obama Administration’s agreement to double motor vehicle fuel efficiency standards and significantly cut greenhouse gas emissions with the support of automobile manufacturers, states, labor unions, environmental and consumer groups, and Congress. Mr. Guzy also led CEQ’s efforts to modernize permitting and environmental review under the National Environmental Policy Act, and counseled federal agencies on how to fulfill their NEPA obligations for dozens of high profile decisions and assisted in resolving NEPA controversies at numerous complicated sites.

Mr. Guzy served as General Counsel of the U.S. Environmental Protection Agency and Counselor to the EPA Administrator during the Clinton Administration. He was a member of the Administrator’s senior policy team, setting regulatory, legislative, and communications strategy. He led efforts to design regulatory approaches to protect children’s environmental health, develop and defend new air quality and motor vehicle standards, defend EPA from Congressional oversight investigations, and protect iconic ecosystems such as the Everglades and Yellowstone National Park. He also authored climate change opinions that were later ratified by the U.S. Supreme Court in its landmark decision finding that greenhouse gases are pollutants under federal law.

Mr. Guzy has also served as the chief legal officer, sustainability officer, and climate strategist for a variety of business organizations

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