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The SEC Climate Rule

Elevate your strategy and plan for interoperability with confidence.

SEC stays its climate rule pending judicial review

While the SEC's stay on the climate rule pauses the need for calculating the impact of certain climate-related events or conditions on the financial statements, the remaining provisions of the rule are required for other reporting regimes – including the EU and international standards as well as the California laws. Companies should continue to move forward according to plan and carry out an interoperability analysis.

Questions you should have answers for:

  • What are our significant near and long-term climate risks?
  • How are we prioritizing investments to transform our business? 
  • How do we organize ourselves for success?
  • How do we quickly mature our collection of data and use of technology?
  • How do we build a 'fit for purpose' governance model and system of controls for non-financial reporting?

Join us for our KPMG Live Event series on the SEC Climate Rule

LinkedIn Live: The Wait is Over – the SEC’s Final Climate Rule is here!

Date: March 12, 2024

Time: 2:30 p.m. ET

Watch Replay

SEC Webcast Part 1: What Does the Rule Require?

Date: March 13, 2024 | Time: 2:00 p.m. ET | CPE: 1 credit
Date: March 26, 2024 | Time: 11:00 a.m. ET | CPE: 1 credit

Watch Replay

SEC Webcast Part 2: The Impact on Companies' Enterprise Strategy and Climate Agenda

Date: April 9, 2024

Time: 11:00 a.m. ET

CPE: 1 credit

Watch Replay

SEC Webcast Part 3: Impact on Companies’ Reporting, Data & Technology and Governance

Date: April 23, 2024

Time: 11:00 a.m. ET

CPE: 1 credit

Watch Replay

SEC Webcast Part 4: Disclosing the Impact of Climate Risks in Financial Statements

Date: May 7, 2024

Time: 11:00 a.m. ET

CPE: 1 credit

Watch Replay

This is not just a compliance exercise, but a unique opportunity to unlock value with investors, customers, and employees. The SEC’s ruling will raise the bar across businesses, demanding deeper sustainability engagement to gain that edge.

Rob Fisher

KPMG US Sustainability Leader

Business implications across the enterprise

The impact of the SEC’s climate rule will span the enterprise and has the power to transform your business. Doubling down on sustainability may lead to more competitive products and services in the transition to a low-carbon economy, greater ability to attract and retain talent, better ability to attract capital, and more. Seize the opportunity to turn sustainability aspiration into action creating a competitive edge that not only mitigates risk but increases shareholder value and value creation. Click on solutions below to explore. 

Strategy, Transformation & Implementation

Organizations need to integrate sustainability into their core business strategies. CEOs can respond to this pressure by investing in an effective sustainability strategy that considers all aspects of business, including operations, accounting, and tax implications.

At KPMG, we understand sustainability engagement must drive financial value. We work collaboratively to understand where strategy can be prioritized and will deliver out-sized gains while ensuring regulatory compliance.

Eric Tresino, KPMG Managing Director Advisory

Reporting

Sustainability reporting goes beyond compliance to tell a company’s sustainability story backed up by financial and non-financial information. Doing so enhances stakeholder trust and drives business resiliency. It’s not just the SEC, but European, state, and local requirements that create intersecting reporting requirements potentially affecting both public and private companies in the U.S. Companies that establish a mature sustainability strategy underpinned by well-controlled data will have a competitive advantage to not only meet these expectations but stand out to stakeholders.

We help our clients navigate this changing landscape and ensure that their reporting meets the highest standards of transparency and accuracy. By embracing the SEC’s climate rule companies can build trust with their stakeholders, differentiate themselves in the marketplace, and drive long-term value creation.

Sam Jeffery, Sustainability Reporting Leader

Assurance

Having a strong reporting strategy helps your company achieve timely and rigorous sustainability reporting.  Our sustainability assurance services will enable your company to deliver confidence to all of your stakeholders.  Our assurance services include limited or reasonable assurance of greenhouse gas emissions, diversity and inclusion metrics, green/social bond use of proceeds, GRI and SASB reports, as well as management developed KPIs.

If you are uncertain as to how your company stacks up against the SEC’s climate proposal, our Ready for Assurance service is a one-time review of necessary base company competencies that can be used to verify whether the conditions necessary for assurance to be performed for an entity over sustainability reporting have been met.  In particular, the KPMG Ready for Assurance service examines an organization’s criteria for sustainability measures and determines if they have the evidence that would be required to support the disclosures they want to make, regardless of the reporting framework.

We are crossing the Rubicon. Climate-related financial disclosures will not be theoretical, but likely a baseline expectation.

Maura Hodge, Sustainability Audit Leader

Climate, Nature & Decarbonization

It’s not a surprise that a recent KPMG report finds that reducing emissions is most associated with higher share prices. Climate change is not just a societal challenge with investors, talent and customers demanding action, but it poses operational and financial risks for businesses. Not living up to commitments can have a reputational impact and can provoke a backlash from stakeholders. And, of course, failure to act means falling short in meeting the climate challenge. To reach goals of any kind, organizations need roadmaps, including near-term milestones and actions to drive a sense of urgency.

I believe that climate change is one of the most pressing issues of our time, and businesses have a critical role to play in addressing it. The SEC’s climate rule represents an important step forward in increasing transparency and accountability around climate-related risks and opportunities. As leaders, we have a responsibility not only in reducing our carbon footprint but also to support policies and initiatives that promote nature-based solutions and the decarbonization of our economy.

Mark Golovcsenko, Sustainability Strategy Leader

Social

Social impact accountability continues to rise in importance. Consumers are focusing more on a company’s sustainability profile. And stakeholders are increasingly requiring a company’s diversity, equity and inclusion metrics, emissions reduction, net zero targets and other sustainability-related data when doing business with a company. Engaging with sustainability is quickly becoming the cost of doing business. And those who don’t engage will lose out – financially and reputationally.

Equity and doing right are not only moral imperatives but also strategic ones given the potential impact of sustainability actions on people, communities, and organizations. Companies that lead in this space will reap outsized rewards.

Charisse Dean, Social Strategy Leader

Deals and Value

At KPMG, we think like an investor, offering better insights that result in better deal outcomes. Drawing on deep sector experience, keen business intelligence, and global resources, our approach combines data, analytics, and technology to maximize deal value and move at deal speed. Our proprietary methodology and tools bring issues that should be examined more closely right to the surface, even within compressed deal timeframes, to give you the confidence to make the best life cycle management decisions.

As business leaders, we understand the importance of delivering value to our clients and shareholders. With the SEC’s climate rule, we see an opportunity to create value by integrating climate considerations into our deal-making processes. By assessing climate-related risks and opportunities, we can help our clients make more informed investment decisions and drive long-term value creation. At the same time, we recognize that addressing climate change is a critical societal change, and we are committed to doing our part to promote sustainability and help transition to a low-carbon economy

Steve Arnold, Sustainability Financial Services Leader

Circular Economy

Businesses are increasingly turning towards a “circular economy model” to help manage regulatory requirements and create sustainable growth for the company. The benefits of this approach include greater efficiency and profitability, less waste and cost, better innovation and stronger relationships with customers. If companies adopt the following three drivers successfully, circular economy brings value to their business.

By requiring companies to disclose their climate-related risks and opportunities, the SEC is creating a powerful incentive for businesses to adopt circular business models that prioritize waste reduction, resource efficiency, and closed-loop systems. Companies can position themselves for long-term success in a rapidly changing business landscape by embracing the circular economy and the SEC’s climate rule.

Blythe Chorn, Sustainability Circular Economy Leader

Sustainable Supply Chain

We help our clients identify and measure sustainability risks, affect change and reduce impact across the end-to-end supply chain, ultimately supporting them reach their sustainability ambitions and positively impact our world. Supply chains are complex networks, which in our globalized world span numerous geographies, climates, governments and societies to connect people to the goods and services they desire. It’s therefore no surprise that these interdependent, multi-nodal networks are challenging to understand and control. We help our clients identify and measure sustainability risks, affect change and reduce impact across the end-to-end supply chain, ultimately supporting them reach their sustainability ambitions and positively impact our world.

As companies seek to address their climate-related risks and opportunities, the sustainability of their supply chains has become an increasingly important consideration. The SEC’s climate rule encourages companies to adopt more sustainable supply chain practices, such as responsible sourcing, energy efficiency, and waste reduction.

Rob Barrett, Sustainable Supply Chain Advisor

Tax

Sustainability is now a chief measure of corporate behavior, with tax playing a key part due to its linkages to environmental, societal, and governance benefits. Tax departments are being challenged to adjust tax strategies and affairs, and to ramp up reporting processes to address transparency demands, demonstrate commitment to a sustainable approach to tax, and take advantage of green tax incentives.

We are closely monitoring the evolving tax implications of the SEC’s climate rule and working with our clients to ensure that their tax reporting accurately reflects their climate-related risks and opportunities. By taking a proactive approach to tax and the SEC’s climate rule, companies can not only enhance their financial reporting but also manage their tax risks and opportunities more effectively.

Timothy Stiles, Sustainability Tax Leader

Governance

Sustainability reporting goes beyond compliance to tell a company’s sustainability story backed up by financial and non-financial information. Doing so enhances stakeholder trust and drives business resiliency. It’s not just the SEC, but European, state, and local requirements that create intersecting reporting requirements potentially affecting both public and private companies in the U.S. Companies that establish a mature sustainability strategy underpinned by well-controlled data will have a competitive advantage to not only meet these expectations but stand out to stakeholders.

Ensuring sustainability reporting is driven by strategy rather than viewed as simply a compliance exercise is an overarching responsibility of corporate boards. Boards are expected to be transparent about how they are overseeing risks and opportunities and companies will need to be clear in their disclosures.

Steven Estes, Sustainability Governance Leader

Are you ready?

Assess your readiness for the new rule using our SEC Climate Rule Diagnostic. With the ability to track your entire climate journey, it provides rapid insights on current compliance, quality, and maturity aligned to our framework across four key phases.

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Assess current state

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Assess current state

Take a 360-degree view of sustainability internally and externally, including conducting materiality assessments to understand your priorities. Our diagnostic approach delivers rapid insights into your current reporting against the proposed SEC climate disclosures, providing an assessment of compliance readiness and disclosure quality.

  • Gather and align publicly available information
  • Early potential identification of disclosure gaps
  • Review and confirm initial disclosure gaps
  • Consolidate and prioritize recommendations
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Build strategy

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Build strategy

Determine where you want to go with sustainability, and your overall objective compared to your peers
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Operationalize

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Operationalize

Put the programs in place to reach targets and commitments, enhancing your data and technology approach to accelerate impact.
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Report and monitor

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Report and monitor

More than compliance, it’s about measuring the pace and success of your organization’s sustainability strategy.
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