Mandatory corporate climate-related disclosure is gaining momentum. A dozen countries including the European Commission are moving forward with mandatory rules that would require companies to disclose information related to climate risk and greenhouse gas (GHG) emissions according to global standards (see our prior analysis). These new rules will apply to food and agriculture companies, some of which have climate footprints as big as entire countries[1] and have faced criticism for misleading voluntary reporting. In this article, we investigate the effect of global climate-related disclosure rules on 15 major meat and dairy companies.
The five meat and 10 dairy companies in this analysis were selected based on IATP’s previous reports which estimate the magnitude of these companies’ total GHG emissions, including the potent GHG methane. Methane has about 80 times more global warming potency than carbon dioxide but is shorter lived in the atmosphere. Due to its short lifespan of about 12 years, targeted reductions in methane emissions can more immediately slow climate change, buying time for reductions across all GHGs.[2] There is a consensus among scientists that a rapid reduction of methane is the most cost-effective way for humanity to limit temperature overshoot past 1.5 degrees Celsius, possibly preventing tipping points and irreversible climate change.
Agriculture is responsible for a significant portion of global methane emissions, with the livestock sector as the single largest contributor (32%). IATP and the Changing Markets Foundation estimated the methane emissions of these 15 companies in 2022 and found that if they were treated as a country, they would be the tenth largest GHG-emitting jurisdiction in the world. Their combined emissions exceed those of oil companies such as ExxonMobil, BP and Shell (see Figure 1).[3]
Despite their enormous climate impact, meat and dairy companies have mostly operated under the radar of mainstream climate policy, evading responsibility to report or reduce their GHG emissions. When major meat and dairy companies do report their emissions, the reporting often lacks transparency, credibility or comparability with other companies.[4]
That could be changing. The network graph below shows that major meat and dairy companies are covered by mandatory climate disclosure rules that would require standardized emissions reporting. Hover over a company node to see which climate disclosure rules it is connected to.
Climate disclosure rules can affect companies at the parent level, where the consolidated parent company must report in alignment with the rule, or at the subsidiary level, where only the subsidiary must report. The table below shows which meat and dairy companies fall under the jurisdiction of different climate disclosure rules, and at which level they are affected.[5] Hover over the cells to find additional information on whether the company (at the parent or subsidiary level) will have to report Scope 3 or provide third party assurance for emissions reporting.[6]
The data used in this analysis was compiled from annual reports, public stock filings and company websites. While IATP has taken care to ensure the data is as accurate as possible, it is not exhaustive. There are significant limitations to the data retrieved from the sources mentioned above, as well as to the availability of information on some companies.[7] Click here for a link to our dataset.
Our analysis shows that all 15 of the major meat and dairy companies will have to report under at least one climate-related disclosure rule. Furthermore, each company is estimated to be impacted by four different climate-related disclosure rules on average.[8]
Although climate disclosure rules are based on agreed-upon frameworks,[9] there are key differences between rules that affect their strength and applicability to agribusiness. The most stringent rules currently in effect call for Scope 3 emissions reporting (which accounts for 90% of agriculture emissions) with third party assurance. Our analysis shows that all but one of the 15 major meat and dairy companies would likely have to report Scope 3 emissions with third party assurance at the parent level by 2028. Canadian dairy company Saputo is currently not exposed to any such rule, but could be in the near future as Canadian financial regulators consider a climate-related disclosure rule for publicly listed Canadian companies.
The EU’s disclosure rule, the Corporate Sustainability Reporting Directive (CSRD), is the most comprehensive rule in terms of coverage of meat and dairy companies, with an estimated 13 of 15 meat and dairy companies covered by the EU CSRD.
As of 2023, five of the major meat and dairy companies in our analysis did not report Scope 3 emissions. Under global climate-related disclosure rules, all five of those companies will be required to report Scope 3 emissions for the first time by 2028.[10]
Legal and political challenges
While the Trump Administration is expected to halt proposed climate disclosure rules at the Security Exchange Commission (SEC), California has approved even stronger climate disclosure rules, and New York is expected to pass new rules in 2025. Furthermore, all five of the meat and dairy companies covered by the SEC rule are also covered by disclosure rules in other jurisdictions.
Strong disclosure rules in California and the EU have attracted legal and political opposition but are currently still intact. In January 2025, the California Air Resources Board (CARB) took steps to begin implementation of their disclosure rule, which would require large public and private companies “operating in California”[11] to report Scope 3 emissions with third party assurance. The EU has faced pressure from members of the Commission to soften or delay the reporting obligations of the CSRD as a proposal for a simplified legislation package gathers steam. Although there is some regulatory uncertainty, many companies are using this momentary pause to internally coordinate in preparation for reporting. Climate disclosure rules are gaining momentum and companies everywhere are preparing to comply.
Conclusion
In the lead-up to COP30, where action to reduce agricultural methane is expected to be a key topic, countries are considering ways to enhance their nationally determined contributions (NDCs) by strengthening climate action in the agriculture sector. Compared to the last round of NDCs submitted in 2020 and 2021, countries have signed on to more commitments aimed at transforming the agriculture sector including the Global Methane Pledge, under which over 125 countries agreed to reduce global methane emissions by 30% by 2030. Effective regulation of meat and dairy companies is key to achieving the necessary methane cuts and embarking on the transformation of the food system needed to meet global climate goals.
While we focus on the 15 major meat and dairy companies in this article, our findings are reflective of the trends across the food and agriculture sector. Many food and agriculture companies, including small and medium-sized enterprises (SMEs), will be affected by new climate disclosure rules coming into effect around the world. As the momentum behind mandatory climate disclosure builds, IATP will be closely tracking their impact on food and agriculture companies, as well as global climate goals.
Footnotes
[1] IATP, Emissions Impossible, 2018. https://www.iatp.org/emissions-impossible
[2] https://www.ipcc.ch/report/ar6/syr/downloads/report/IPCC_AR6_SYR_LongerReport.pdf p. 95
[3] Data originally from Emissions Impossible: Methane Edition, 2022.
[4] IATP, “Emissions Impossible Series,” accessed January 2025. https://www.iatp.org/emissions-impossible-series
[5] It is not always clear if a climate disclosure rule will affect a company at the parent or subsidiary level but the data in this analysis reflects our best estimation.
[6] For more detailed information on the requirements of different climate disclosure rules, see our previous publication.
[7] Availability of relevant information for this analysis varied by company for a variety of reasons. Private companies are generally more difficult to find information on, and most companies do not provide a list of subsidiaries or geographic operations, which is necessary to determine coverage under several climate disclosure rules. Information on non-EU companies’ revenues in the EU, which is necessary to determine coverage under the EU CSRD, is limited.
[8] This figure includes climate disclosure rules that impact a company at the subsidiary level.
[9] See the Taskforce on Climate-related Disclosures (TCFD) and the International Sustainability Standards Board (ISSB).
[10] Note that Tyson Foods partially reported Scope 3 emissions in 2019 but has not reported Scope 3 emissions since.
[11] See the text of the California climate disclosure rules, SB 261 and SB 253.
Visualizations made with Flourish.
