Strategic Focus: Complying With The SEC Climate Disclosure Rule

Executive Summary

March 21, 2022 marked the publication of the proposed climate disclosure rule from the US Securities and Exchange Commission (SEC) – a new and pivotal measure in the US that would require public firms to enhance their standardized climate-related disclosures. Following the end of the comment period in June 2022, the SEC is aiming to publish its final rule in the ‘Federal Register’ by mid-October 2022, in what will be a landmark moment for climate change disclosures – but also a catalyst for criticism from firms, banks, investors, politicians and other stakeholders. Bank of America and Wells Fargo, for instance, as well as members of the US government, have written extensively to the SEC calling for it to revise the rule, asserting that in its proposed form, it will require myriads of data that are too complex to collect and calculate and may not be necessary for investors. This report will consider the challenges issuers may face when following the SEC’s proposed rule. It will discuss the various compliance requirements and the implications these pose for the C-Suite, heads of sustainability and boards of directors.