SB 253: What are your organization’s emissions? SB 253, the Climate Corporate Data Accountability Act,…
The 90-Day GHG Data Readiness Checklist
Get your utility and emissions data ready before 2027 reporting pressure hits
If your company wants to work with large enterprise buyers in 2027, now is the time to get your greenhouse gas data in order.
For many organizations, carbon footprint reporting is no longer just a sustainability initiative. It is becoming a customer requirement, a procurement issue, and a compliance-readiness question.
California’s SB 253 and SB 261 are adding urgency. SB 253 applies to large companies doing business in California with more than $1 billion in annual revenue and requires annual disclosure of Scope 1, Scope 2, and Scope 3 greenhouse gas emissions. SB 261 applies to companies doing business in California with more than $500 million in annual revenue and requires biennial climate-related financial risk reporting.[1]
Even if your company is not directly covered, your customers may be.
That matters because large companies often need emissions data from suppliers, vendors, property owners, manufacturers, and service providers to complete their own reporting. If you sell to Fortune 500 companies, especially companies based in or doing business in California, you may soon be asked to show your carbon footprint, answer emissions-data questions, or demonstrate that your organization is preparing for climate disclosure requirements.
The question is simple:
If a customer asked for your GHG data today, could you respond quickly, accurately, and confidently?
If the answer is “not yet,” the next 90 days are the right time to get ready.
1. Identify who may ask for your emissions data
Start with your customer list.
Look for large enterprise customers, public companies, government buyers, and organizations based in or doing business in California. These are the customers most likely to add carbon footprint, utility data, climate risk, or emissions questions to supplier forms and RFPs.
Ask:
- Do we sell to Fortune 500 or large enterprise customers?
- Do we respond to RFPs that include ESG, sustainability, or emissions questions?
- Have customers already asked for energy, utility, or carbon data?
- Are any major customers subject to California climate disclosure rules?
- Do we know who inside our company owns the response when these questions arrive?
This step helps move GHG readiness from an abstract compliance issue to a practical business issue. If your customers need better emissions data, your ability to provide it can affect renewals, procurement conversations, and future opportunities.
2. Gather your core utility data
For most organizations, GHG readiness starts with utility data.
Electricity, natural gas, water, waste, and fuel records are often the foundation for emissions reporting. But in many companies, that data is scattered across departments, vendors, buildings, spreadsheets, and billing portals.
Before 2027 planning begins, review whether you have complete, usable utility records for the current year.
Checklist:
- Collect utility bills for all locations.
- Confirm account numbers, meters, addresses, and billing periods.
- Identify missing, estimated, or inconsistent bills.
- Separate electricity, natural gas, water, waste, and fuel data.
- Note which utilities are controlled by landlords, tenants, or third parties.
- Create a central place for facilities, finance, and sustainability teams to access the data.
The goal is not just to collect bills. The goal is to create a data trail that can support reporting, customer requests, audits, and internal decision-making.
3. Map your data to Scope 1, Scope 2, and Scope 3
Once the data is collected, the next step is to understand what type of emissions activity it supports.
Scope 1 emissions generally come from sources your organization owns or controls, such as onsite fuel combustion. Scope 2 emissions come from purchased energy, such as electricity. Scope 3 emissions come from value-chain activity, which may include suppliers, transportation, purchased goods, business travel, and other indirect sources.
For many companies, Scope 3 is where customer pressure shows up first. Large organizations preparing their own emissions disclosures may need better data from suppliers to understand their value-chain impact.
Checklist:
- Identify likely Scope 1 sources, such as onsite fuel use.
- Identify electricity and purchased energy sources for Scope 2.
- Flag supplier, logistics, travel, and purchased-goods data that may support Scope 3 questions.
- Document assumptions, exclusions, and gaps.
- Determine whether your current process can be repeated next quarter or next year.
This mapping does not need to be perfect on day one. But it does need to be organized enough that your team knows what data exists, what is missing, and what needs to improve.
4. Check for gaps before January
The worst time to find missing data is after a customer asks for it.
Use the final 90 days of the year to find problems while there is still time to correct them. Missing bills, duplicate accounts, mislabeled meters, and inconsistent location names can all create delays when reporting deadlines or customer requests arrive.
Checklist:
- Which locations have incomplete utility records?
- Are any meters unassigned, mislabeled, or duplicated?
- Are there buildings where the landlord controls utility access?
- Are any bills estimated rather than actual?
- Can finance, facilities, and sustainability teams see the same information?
- Can the data be exported into a format useful for reporting?
- Are there clear notes explaining any gaps or assumptions?
A good GHG readiness process does not hide imperfect data. It identifies the gaps early and creates a plan to close them.
5. Prepare a customer-ready response
A customer may not ask for a full emissions report right away. The first request may arrive as a supplier questionnaire, procurement form, RFP, or renewal conversation.
Be ready with a clear, practical response that explains:
- What energy and utility data you track
- What reporting period the data covers
- Which locations or operations are included
- Which emissions categories you can currently support
- What methodology or reporting framework you are using
- What gaps remain
- What improvements are already underway
This is where GHG readiness becomes a competitive advantage. A company that can respond quickly and clearly looks more prepared, lower-risk, and easier to work with.
For enterprise customers, that matters.
6. Turn GHG reporting into an operating rhythm
GHG reporting should not be a once-a-year fire drill.
The companies that will be best prepared in 2027 are the ones that build repeatable utility-data and emissions-reporting processes now. That means monitoring usage, catching missing bills, normalizing data across locations, and turning operational records into reports that leadership can trust.
A strong process helps teams:
- Reduce last-minute reporting stress
- Improve customer and RFP responses
- Support SB 253 and SB 261 readiness
- Identify energy, water, and cost-saving opportunities
- Build confidence in the numbers behind climate and emissions claims
- Compliance may be the trigger. But better data creates value beyond compliance.
It gives finance, facilities, sustainability, and executive teams a clearer view of how the organization uses energy, where risks exist, and where improvements can be made.
Get ready before the request arrives
The next wave of GHG reporting pressure will not only come from regulators. It will come from customers, investors, procurement teams, and enterprise partners that need better emissions data from the companies they work with.
If you wait until the request arrives, you may already be behind.
The next 90 days are an opportunity to get organized: collect the right utility data, identify gaps, map emissions categories, and prepare a customer-ready response before 2027 reporting pressure accelerates.
Verdafero helps organizations track, report, and reduce environmental impact by securely monitoring utility data and producing fast, accurate Scope 1, 2, and 3 emissions reports. With patented utility monitoring software and sustainability consulting support, Verdafero helps teams turn scattered utility records into clearer reporting, better decisions, and measurable progress.
If your organization is ready to make GHG reporting easier to manage and easier to trust, visit Verdafero’s website to learn more and schedule a demo. See how utility data can become a clearer path to faster reporting, better customer responses, and measurable environmental progress.

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