Success Story: How Low Emitting Companies Evaluate Climate Risk Under SB 261

The Client

The client is a nationally recognized litigation firm headquartered in Houston, with offices in Los Angeles, New York and Seattle. As a professional services organization, the firm’s primary assets are its people and its ability to operate reliably across markets rather than owned real estate or physical infrastructure. While the firm does not own its office properties, its distributed operations and presence in climate-exposed regions elevate the importance of workforce continuity, employee safety and defensible climate risk governance.

The Challenge

California’s Senate Bill 261 (SB 261) requires large U.S. companies operating in the state to disclose climate-related financial risks and mitigation strategies in alignment with the Task Force on Climate-related Financial Disclosures (TCFD) framework. These requirements apply across all sectors, regardless of business model, asset intensity or emissions profile. Applicability is not determined by emissions intensity or asset ownership, and companies should not rely on their enterprise profile, such as being service-based, asset-light or traditionally low-emitting, as an indicator that they fall outside the scope of the law.

For a professional services firm, compliance requires translating climate-related physical and transition risks into a context in which primary exposures are offices, workforce location, technology reliance and continuity of client service. As a first-time respondent, the firm needed a structured, repeatable approach to climate risk assessment that identified material physical risks across its office portfolio and evaluated transition risks related to regulatory developments, insurance, technology, reputational considerations and evolving client expectations.

The Process

The engagement focused on moving the firm from informal practices to a documented, evidence-based climate risk framework suitable for regulatory scrutiny and long-term operational resilience. Given the firm’s industry and operating model, climate risk exposure is often assumed to be limited, particularly for organizations that do not own physical assets. As part of the engagement, Weaver broadened this perspective by identifying the areas where climate-related disruption could affect the firm’s ability to function, serve clients and protect its workforce.

Weaver performed a comprehensive, TCFD-aligned climate risk assessment across the firm’s office portfolio, combining physical and transition risk analysis with structured documentation and evidence gathering.

The engagement included a location-based physical climate risk assessment using FEMA’s National Risk Index to evaluate exposure to all 18 natural hazards. Weaver developed hazard-specific risk profiles and identified material vulnerabilities related to heat, hurricanes, riverine flooding, earthquakes, wildfires and severe wind events. Visual analytics, including comparative risk charts and a 2050 sea-level rise map, were used to clearly communicate relative risk severity and employee-weighted exposure.

In parallel, Weaver assessed transition risks across technology, market, reputational and policy and legal categories. This review incorporated the firm’s IT governance, cloud infrastructure, cybersecurity controls, insurance coverage, emergency response capabilities and evolving sustainability expectations from clients and regulators.

The review began with preparedness for disruption and continuity, including emergency response planning, remote-work readiness and the firm’s ability to maintain secure access to systems and client data during weather-related events or facility outages.

Weaver then assessed risks tied to the firm’s physical workspace and day-to-day activities, including building certifications and performance (such as LEED Gold and ENERGY STAR), waste and recycling programs and digital workflows that support the firm’s hybrid operating model and reduce reliance on physical infrastructure.

To support audit defensibility and repeatability, Weaver coordinated facilities, accounting, IT and office leadership to identify, collect and organize underlying evidence. Standardized templates were developed to support future tracking of utility usage, emissions and climate-related data.

Finally, governance roles and oversight structures were documented and mapped to TCFD expectations to establish clear accountability and enable ongoing integration of climate risk considerations into enterprise risk management processes.

The Deliverables

The engagement delivered a concise, SB 261-ready Climate Risk Assessment supported by documented methodologies, visual hazard analytics and a consolidated current-state inventory. Key outputs included a physical and transition risk assessment, a defensible evidence package and a targeted gap analysis with prioritized recommendations.

Together, these deliverables established the firm’s first formal climate risk baseline and created a repeatable, scalable and auditable framework, positioning the firm to respond efficiently to future reporting requirements and expanded climate-related disclosures without rework.

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Coauthored by Holly Roozrokh

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