Oversight of climate disclosures

Despite the sense of relief that many companies initially felt with the SEC’s stay of its climate disclosure rules, the pause is unlikely to temper the forces demanding climate disclosures by other means. Whether the SEC rules are upheld, struck down in whole or part, amended, or abandoned, pressure from investors, stakeholders, and other regulators continues to drive the momentum toward detailed climate disclosure requirements.

Companies face a proliferation of new and complex climate disclosure mandates—including the SEC rules, state laws (with California leading the way), international laws and standards, or some combination of these. As a result, companies will have to comply with multiple inconsistent laws and will need to determine how best to structure their compliance and disclosure programs.

Given these near-term demands and growing consensus around common, comparable reporting standards—like the European Sustainability Reporting Standards or the sustainability reporting standards of the International Sustainability Standards Board (ISSB), which incorporate the Task Force on Climate-related Financial Disclosures’ (TCFD’s) standards and Greenhouse Gas Protocol—we highlight key areas of focus for boards and audit committees as the SEC stay and broader regulatory landscape unfolds.