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Understanding the SEC’s climate rule

Defining Issues | April 2024

Top 10 questions on the final rules – covering scope, Reg S-X and Reg S-K requirements, effective dates and more.

On April 4, 2024 the SEC stayed the climate rule pending judicial review – read our web article.

The specific events that culminated in adoption of the climate rule on March 6, 2024, began in March 2021 when the SEC requested public input on climate-related disclosures to help evaluate its then current rules and guidance. This was followed in March 2022 by issuance of the SEC’s proposed climate reporting rules. Over the last two years, the SEC considered more than 4,500 unique comment letters (over 20,000 letters in total) as it drafted its final rules.


SEC Release Nos. 33-11275 and 34-99678

Final rule: The Enhancement and Standardization of Climate-Related Disclosures for Investors AGENCY: Securities and Exchange Commission

  • Registrants with Exchange Act reporting obligations pursuant to Exchange Act Section 13(a) or Section 15(d), and companies filing a Securities Act or Exchange Act registration statement
  • Includes Foreign Private Issuers; excluding Canadian issuers reporting under the Multijurisdictional Disclosure System and asset-backed issuers

Phased transition

The following table summarizes the compliance dates for registrants based on filer status for both annual reports and registration statements that are required to include information for the full fiscal year indicated in the table.

For fiscal years beginning in calendar year:




Financial statement disclosures




Climate risk disclosures

Climate risk disclosures, except those below




Disclosures in the Specific quantitative disclosures section




GHG emissions

Scopes 1 and/or 2 disclosures




Limited assurance




Reasonable assurance




Inline XBRL





1.      Large accelerated filers

2.      Accelerated filers (except smaller reporting companies (SRCs) and emerging growth companies (EGCs))

3.      Non-accelerated filers

Top 10 questions

  1. Who and what are in scope?
  2. At a glance, what’s required where?
  3. What financial statement disclosures are required?
  4. What GHG emissions disclosures are required?
  5. What climate risk disclosures are required?
  6. How do the different disclosures connect?
  7. What are the implications for controls?
  8. When must registrants comply?
  9. How do the rules compare to other frameworks?
  10. What do you need to do now?

Download the document :

Understanding the SEC’s climate rule

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Meet our team

Image of Julie Santoro
Julie Santoro
Partner, Dept. of Professional Practice, Sustainability, KPMG US
Image of Maura Hodge
Maura Hodge
KPMG Sustainability Reporting Leader, KPMG US

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