“We never have 100 percent certainty. We never have it. If you wait until you have 100 percent certainty, something bad is going to happen on the battlefield — that’s something we know.”

—General Gordon R. Sullivan, former U.S. Army Chief of Staff

General Gordon R. Sullivan’s core leadership lesson—that you never get 100% certainty before you must make hard choices—applies directly to carbon disclosure. “Waiting to see” how the SEC climate rule and litigation unfold before building carbon data, governance, and reporting systems may feel prudent. In fact, it’s precisely the kind of delay Sullivan warned about.

When people say they are “waiting for clarity” they’re usually trying to avoid three things:

• Investing in systems that might not be “exactly right”
• Burning scarce staff time on something that feels like a moving target
• Getting ahead of their board, members or ratepayers.

These are legitimate concerns. But the choice to wait misses a simple reality: certain foundational capabilities are needed no matter what the final rules look like–and building these foundational capabilities does not happen overnight.

Once the SEC climate rule (or its successor) finally settles, markets, investors, and auditors will move fast. Organizations that used the “uncertain” period to build foundational capabilities will be ready. Those that waited for perfect clarity will be scrambling—paying more, moving faster, and taking on more risk

Foundationally, companies already know they will need:

• Reliable carbon and energy data as systematically documented, accurate, granular and auditable as possible;
• Governance and accountability systems that treat energy, climate and carbon data like financial data;
• Controls and processes that can survive auditor and investor scrutiny;
• Scalable systems that integrate with finance and risk;
• Communication, training and change readiness.

All of these foundational capabilities are “no-regrets” moves– they make your organization better. Strong carbon an energy data improves cost management and operational efficiency. Clear governance and controls reduce surprises and strengthen board and investor confidence. Better systems and documentation make audits smoother and free up staff time. Even if the rules shift, you’re left with an organization that understands its risks and opportunities more clearly, can move faster with less drama and is better positioned to attract capital, talent and partners. So the question isn’t whether or not to build those capabilities–it’s whether you do it calmly now or in a panic later.

Even if the SEC’s Rule never fully takes effect, the overall direction of disclosure is still moving, everything in the same direction. California has adopted SB 253 (the Climate Corporate Data Accountability Act) and SB 261 (the Climate-Related Financial Risk Act). Globally, over 30 jurisdictions are adopting or moving toward the ISSB’s IFRS S1 and S2 sustainability disclosure standards, with many aligning national rules to a framework where climate, carbon and energy data are decision useful, auditable and governed like financial data.

So what are the foundations to build now?

• Get your data house in order. 1) Have a clear map of where your energy, fuel and process data lives and who owns it; 2) A way to pull that data on a repeatable schedule; 3) A basic methodology for estimating material emissions sources, even if you refine the factors later. If you are subject to Californias SB 253 and SB 261, this is non-optional by 2026-2027. But even if you are not, investors and partners are and will be increasingly asking you for consistent, comparable data.
• Clarify governance and oversight: Regulators and standards are converging on the idea that climate and sustainability disclosures are governance issues–not marketing exercises. 1) Decide who owns climate-related data and reporting internally; 2) Make sure the board or an appropriate committee receives regular updates on climate, carbon and energy risk; 3) Document how climate-related information is reviewed and approved before it shows up in financial filings, bond offerings, member communications or grant applications.
• Align with global frameworks, not just one rule. ISSB standards (IFRS S1 and S2) are becoming the reference point for many jurisdictions and investors. Time well spent here includes: 1) Mapping your existing disclosures (MD & A, ESG reports, TCFD-style reports, bond offering language) against ISSB-style topics: governance, strategy, risk management, and metrics/targets. 2) Identifying obvious gaps: where do you talk about climate qualitatively but have no metrics? Where do you have metrics but no governance story? 3) Future-proof your processes by starting to structure internal reporting so that it can be easily adapted to ISSB, California, SEC or other frameworks without rebuilding from scratch.

Working on foundational capabilities now doesn’t lock you into a single technology path. It will make your organization stronger and will give you a way to say “yes” quickly when the right opportunity or requirement appears.

Even if your not directly in scope for SB 253, SB 261 or the SEC rule, you can easily be in scope indirectly through

• Vendor questionaires
• Lending covenants
• RFP requirements
• Due diligence for mergers, acquisitions and investments.

Being ready with these foundational capabilities–good data, basic governance, a creditable narrative–will turn those requests from a one-off headache into an opportunity to consistently differentiate.

General Sullivan’s warning wasn’t about rushing blindly. It was about recognizing that in complex, high-stakes environments, waiting for 100% certainty is itself a form of risk.

Want help turning “foundational work” into a practical roadmap for your company, cooperative, farm, or community? Now is the right time to begin—contact us.