Climate Risk: SEC’s Mandatory Climate Disclosures Proposal

The SEC’s proposed mandatory climate disclosure rules are clearly seen as historic in nature, and one of the most significant U.S. environmental actions to date. The goal of the SEC is that such disclosures will provide more consistent, comparable, and reliable information for investors to evaluate climate-related risks. Both the quantitative and qualitative elements of the proposals would have far-reaching impacts to public companies if adopted as proposed – in formalizing how they govern, monitor, measure, analyze and report climate risk activities and impacts. Companies should quickly take appropriate action, including:

• Establish/assess GHG emission metrics and roadmap for reporting (Scope 1 and Scope 2, and Scope 3 if material or included in a reduction target)
• Formalize climate-risk governance and risk management (inclusive of risk identification, the measurement and the monitoring and tracking of required metrics, as well as commitments, targets and progress and the process for evaluating climate risk and controls)
• Evaluate climate-related risks and opportunities (aligning with TCFD, as appropriate). Consider both physical and transition risks and the use of scenario analysis (as appropriate) in terms of operational resiliency and financial impacts (capital and operating expenditures).