Recalibration, Not Retreat: U.S. Sustainability Disclosure in Five Charts 

The full paper is available for download from ISS-Corporate’s resources page.

The past two years have tested corporate sustainability programs in the United States. Scrutiny has sharpened inside organizations weighing cost and competing priorities, and in the public arena, where sustainability has become a contested feature of policy and political debate. For corporate practitioners, the central question is a practical one: how are companies responding?

The data offers a clearer answer than the headlines suggest. Disclosure practices are considerably more established than a decade ago, and prevalence across most indicators confirms it. Momentum has cooled from the peak years, but the picture is one of recalibration rather than retreat – continued growth across many topics, selective and strategic expansion in others, and measured declines in a few, most visibly within human capital management.

The regulatory backdrop is mixed. The SEC has proposed rescinding its 2024 climate disclosure rule and, separately, has stepped back from its long-standing role reviewing shareholder-proposal exclusions under Rule 14a-8. California, meanwhile, continues to implement SB 253, with first-year Scope 1 and Scope 2 emissions reporting now expected in November 2026, while enforcement of SB 261’s climate-related financial risk reporting requirement remains paused pending litigation even though CARB has opened a voluntary submission process. Several other states have also advanced comparable climate disclosure measures. Federal executive action has also targeted diversity, equity, and inclusion programs, including within the federal government and among federal contractors.

The five charts that follow trace this recalibration in detail. ISS-Corporate reviewed corporate sustainability disclosures in five key areas across U.S. large-cap (>$10B) and mid- and small-cap (<$10B) companies from 2024 to 2026. The U.S. path is steadier than the debate implies, more measured, perhaps, than the trajectory elsewhere, but holding. What endures against these headwinds is what companies have judged relevant to their business, supported by market expectations, stakeholder priorities, and internal decision-making rather than mandate alone.

Key takeaways

• Despite political and regulatory headwinds, the rates of disclosure among U.S. companies held steady or expanded across four key sustainability categories: climate, environmental management, human rights and supply chain, and reporting infrastructure. 
• Human capital, the fifth category in the study, saw a decline in disclosure rates. However, the decline was mostly concentrated in one metric, employee demographics.