Compare Esg Disclosure Against Regulatory Requirements

---
name: compare-esg-disclosure-against-regulatory-requirements
task_id: environmental-esg/compare-esg-disclosure-against-regulatory-requirements
description: Guides gap analysis of a draft ESG report by walking each applicable regulatory framework's disclosure requirements systematically rather than treating ESG disclosure as a single undifferentiated category.
activates_for: [planner, solver, checker]
---

# Skill: ESG Disclosure Gap Analysis Memorandum

## 1. Subject-matter triage
- Identify which frameworks actually apply to the entity, group, or reporting period before analyzing content.
- Treat SEC climate disclosure requirements, California climate statutes, and EU corporate sustainability reporting as separate regimes with separate scope tests, timing, and disclosure elements.
- If more than one issuer, subsidiary, or reporting perimeter is implicated, assess each separately before synthesizing overlap.
- If the source set is incomplete, distinguish missing support from true disclosure noncompliance.

## 2. Failure modes the skill is correcting
- Conflating multiple regulatory regimes into one generic ESG standard instead of analyzing each framework on its own terms.
- Flagging missing topics without checking whether the supporting documents actually substantiate the required disclosure.
- Treating emissions disclosure as one bucket rather than separating direct, indirect energy, and value-chain emissions, together with the relevant methodology, boundary, estimation, and exclusion issues.
- Missing affirmative misstatements, overstatements, or assurance claims that create risk beyond omission.
- Failing to connect each issue to the governing authority, the source document cross-reference, and the practical consequence for the client.
- Producing diagnoses without clear remediation steps tied to the responsible function and timing.

## 3. Legal frameworks / domain conventions that apply
- SEC climate disclosure framework: confirm current status, applicability, subject matter, and terminology; do not assume a universal climate rule where none exists.
- California climate-disclosure statutes: analyze each enactment separately, including entity scope, timing, emissions reporting, and climate-risk reporting obligations.
- EU CSRD / sustainability reporting regime: assess scope, double materiality, and the applicable reporting standards.
- GHG accounting conventions: distinguish operational boundaries, emissions categories, estimation methods, exclusions, restatements, and assurance-related claims.
- Climate-risk disclosure conventions: organize around governance, strategy, risk management, and metrics/targets; separate physical and transition risks where relevant.
- Assurance conventions: verify that the assurance scope matches the disclosure claim and that the standard or level of assurance is not overstated.
- Target-setting conventions: assess baseline, methodology, progress, comparability, and validation status.
- Cite the controlling authority for each legal proposition or framework element relied upon; do not state a conclusion without naming the governing rule, statute, regulation, or standard.

## 4. Analytical scaffolds
- For each applicable framework, run a requirement-by-requirement comparison against the draft report.
- For each requirement, state: the governing requirement, the draft’s current treatment, the gap, and the remediation recommendation.
- For each issue, include:
  - severity on a uniform ordinal scale defined once at the start,
  - the specific source-document support or contradiction,
  - the related disclosure, schedule, data set, or supporting exhibit that interacts with it,
  - the downstream legal, regulatory, operational, or litigation consequence.
- When quantitative claims appear in the draft, test them against the supporting documents and flag discrepancies, unsupported extrapolations, and inconsistent denominators or boundaries.
- For emissions disclosures, verify the report distinguishes the relevant emissions categories, explains methodology and boundaries, and discloses assumptions or exclusions that affect comparability.
- For climate-risk disclosures, verify governance, risk identification, scenario analysis, and any quantified impacts are described at a level matching the governing regime.
- For targets and transition plans, verify baseline year, metric, progress, and external validation or assurance status.
- If the issue depends on more than one period, entity, scenario, or reporting boundary, enumerate the relevant items first and then analyze each one separately.

## 5. Vertical / structural / temporal relationships
- Multi-jurisdiction reporting may require different content for the same underlying topic; compliance with one regime does not satisfy another.
- Parent and subsidiary reporting obligations may diverge; evaluate the reporting perimeter expressly rather than assuming group-wide equivalence.
- Assurance may need to occur before publication for some statements or may cover only part of the reported dataset; flag scope mismatches.
- Time-sensitive obligations should be assessed against the relevant filing date, disclosure date, or compliance deadline in the source materials.
- Where supporting documents contain a different entity name, period, methodology, or boundary than the draft, treat that as a material alignment issue.

## 6. Output structure conventions
- Draft the response as a memo, not a checklist dump.
- Use a concise structure with: Executive Summary, Framework-by-Framework Gap Analysis, Cross-Cutting Data Integrity and Support Issues, and Remediation Roadmap.
- Define the severity scale once near the top and apply it consistently to every issue.
- For each framework, use a structured table or numbered list with columns or fields for requirement, draft status, gap, severity, source support, consequence, and fix.
- Make the remediation section action-oriented, with each recommendation tied to the responsible role and an urgency or timing anchor drawn from the record when available.
- Separate immediate pre-publication fixes from longer-term disclosure program improvements.
- End with a Recommended Actions section that states the next steps plainly and operationally.
- Use the filename specified in the task instructions.