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Sustainability reporting & the SEC climate rule in TMT

The SEC climate rule is accelerating the need to close the gap between sustainability reporting strategy and execution.

The SEC Climate Rule

As global organizations face increasing regulatory pressure to disclose information about environmental, social and governance (ESG) impacts, risks, and opportunities, the vast majority of technology, media, and telecommunications (TMT) companies are set to spend more on sustainability initiatives over the next three years. Yet despite the opportunity to enhance financial performance, and the SEC climate rule that mandates reporting on climate-related risks, TMT organizations are facing real challenges with executing their ESG strategy.

KPMG conducted a deep dive on where organizations are investing in the coming years to maximize financial value while complying with disclosure requirements. For TMT companies, these areas are in ESG data collection and management tools as well as in employee training.

The tax function specifically is both a driver of, and measure of, sustainability. As such, tax is a crucial component of ESG planning and execution.

The challenges TMT organizations face integrating sustainability into their broader business structure center around internal silos and divergent priorities. To address these, many companies are planning to restructure teams and outsource core ESG reporting.

Key statistics about TMT companies


will increase their ESG investment in the next 3 years


believe they are ahead of their peers in ESG reporting


still use spreadsheets to manage their ESG data


plan to use AI to improve ESG data collection


will outsource core ESG reporting in the next 3 years

Six steps to improve ESG reporting and strategic integration

There are several actions TMT organizations can take to close the gap between strategy and execution with sustainability and ESG initiatives.


Assess your readiness for the final SEC Climate Rule. Your entire climate journey can be tracked using the KPMG SEC Climate Rule Diagnostic. The tool provides rapid insights on current compliance, quality, and maturity aligned to our framework across four key phases.


Set your sustainability ambitions. Collectively agree upon a sustainability strategy for each of your material sustainability topics, establish action plans, and determine how to measure success. These actions link sustainability to your business strategy, and this information is required for regulatory reporting.


Invest in ESG talent, including training and education for employees. Improve sustainability reporting capabilities by investing in ESG personnel who can manage reporting processes, data collection, and analysis. Create a culture of ESG awareness through employee training and education. This knowledge will help you execute on sustainability goals within the broader business context.


Design a holistic ESG technology architecture. Sustainability information needs are ever evolving; having a structured but flexible ESG data architecture, like a data lake, will allow you to adjust efficiently to new and changing reporting requirements.


Restructure teams to better align sustainability goals with business strategy. Address structural challenges by redefining roles and responsibilities and identifying leaders and subject matter experts for effective implementation and efficient reporting.


Seek external support. To support internal capabilities and accelerate progress, consider outsourcing core sustainability reporting responsibilities.

Dive into our thinking:

Sustainability reporting at TMT companies

Learn where TMT companies are investing in sustainability, their challenges, and steps to improve reporting.

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