Status checked November 10, 2026. Climate disclosure rules were changing that week: check the sources linked here before treating anything as final.
What ESG reports ask of a building
Most frameworks ask a building for the same handful of numbers:
- Energy: electricity, gas and other fuels, by building and over the full year.
- Emissions: Scope 1 from fuel burned on site, and Scope 2 from the electricity, steam and chilled water bought. Both are calculated from metered energy.
- Water: withdrawal and use, and in some frameworks by source.
- The indoor environment: air quality, thermal comfort and the measures taken for the people inside, under the social pillar.
The differences between frameworks are in how much of the portfolio the data must cover, and who checks it.
Where each framework stands in November 2026
| Framework | Status | What it asks of facility data |
|---|---|---|
| California SB 253 | First Scope 1 and 2 reports due November 10, 2026. On November 9, the Ninth Circuit upheld Scope 1 and 2 reporting and blocked Scope 3 (opinion) | Scope 1 and 2 emissions for companies with more than $1 billion in revenue that do business in California. No assurance in the first cycle; CARB has proposed limited assurance from 2027 and reasonable assurance from 2030 |
| California SB 261 | Blocked by the same November 9 ruling | Climate risk reporting, not in force |
| SEC climate rule | Never took effect. The SEC proposed rescinding it in May 2026 (SEC) | Nothing at present |
| GRESB real estate assessment | 2026 cycle (reference guide) | Energy, emissions, water and waste, scored on coverage by floor area and time, like-for-like change, certifications and external review of the data |
| CDP | 2026 cycle; aligned with IFRS S2 (CDP) | Emissions and energy, often requested by customers of their suppliers |
| SASB Real Estate | Now maintained by the IFRS Foundation | Energy data coverage as a share of floor area, and like-for-like change in energy use |
| GRI | GRI 302 (energy), 303 (water) and 305 (emissions) are current; GRI 103 and GRI 102 replace 302 and 305 from January 1, 2027 (GRI) | Energy, water and emissions, with methods disclosed |
| ISSB (IFRS S1 and S2) | Adopted or under way in about 37 jurisdictions as of September 2025, not the US; it absorbed the TCFD recommendations after the TCFD disbanded in 2023 (IFRS) | Climate-related disclosures, including Scope 1 and 2 |
| EU CSRD | Narrowed in 2026 to EU companies with more than 1,000 employees and €450 million turnover. A non-EU parent is in scope with more than €450 million EU turnover and an EU subsidiary or branch above €200 million, reporting from financial year 2028 (EU Council) | Limited assurance of reported data |
Why measured data beats estimated data
Estimates creep into ESG reports in predictable places: tenant spaces with no meter of their own, buildings on a shared campus meter, central plants that serve several buildings, and months when a bill went missing. Each one is filled by an allocation or an estimate, and each one is a question for an auditor.
Measured data closes those gaps in three ways:
- Coverage. GRESB scores, and SASB asks companies to disclose, how much of the portfolio’s floor area is covered by actual data. Metering the uncovered areas raises the number directly.
- Like-for-like comparison. Showing that a measure reduced energy use takes continuous data from before and after the change, on the same building.
- A trail for assurance. Under the assurance CARB has proposed for 2027, an auditor traces a reported number back to its source. A time-stamped reading from a named meter is easier to defend than a spreadsheet allocation.
Utility bills and whole-building meters still count as measured data for most frameworks. Cognituv Connect isn’t a required source for any of them; it fills the gaps the bills leave.
Where Cognituv fits
Cognituv Connect reads the utility meters you already have through a meter pulse reader, and adds electrical submeters, current sensors and water flow meters where a building, tenant or system has none. Every reading is time-stamped and kept against a baseline agreed for your site, and can be exported or sent to other systems by webhook.
Cognituv UV-C cuts chemical use, water and energy at the source, and each of those lands in the data an ESG report asks for. Cognituv Grid runs on the coil with no chemicals, for fewer chemical cleanings and cleaner coils that move air and heat as designed, and water treatment UV-C works with no chemical additives. Cognituv Connect measures coil pressure drop, energy and water against the baseline, so a like-for-like comparison shows the gain.
Frequently asked questions
Are utility bills good enough for ESG reporting?
For most frameworks, yes: bills and whole-building meters count as measured data. Submeters matter where bills don’t reach, such as tenant spaces, shared systems and buildings on a campus meter, and where you need to show which measure changed the numbers.
What’s the difference between Scope 1 and Scope 2?
Scope 1 covers emissions from fuel burned on site, such as natural gas in boilers. Scope 2 covers emissions from the electricity, steam, heating and cooling a site buys. Both start from metered energy use.
Does Cognituv Connect calculate emissions?
Cognituv Connect records energy and water use. Emissions are calculated from that use with the emission factors your reporting standard specifies, usually in your ESG software or by your consultant.
We aren’t in California. Why does SB 253 matter?
It applies to companies with more than $1 billion in revenue that do business in California, wherever they’re based. And even outside it, GRESB investors, CDP and large customers already ask for the same Scope 1 and 2 data.
Does GRESB accept estimated data?
GRESB scores data coverage by floor area and by time, and scores like-for-like change on continuous data. Check its current reference guide for how estimates are treated: metered coverage is the more reliable path to the points.
Rule status checked November 10, 2026, and some of it was changing that week. Confirm with the regulator, your auditor or counsel before you rely on any date here. Nothing here is legal or accounting advice. Updated November 10, 2026.