SEC disclosure guidance on climate-related risks remains

Applicability

SEC Release Nos. 33-9106; 34-61469

Commission Guidance Regarding Disclosure Related to Climate Change

Public companies, including foreign filers

In March 2024, the SEC adopted its final climate rule. However, the rule was quickly met with legal challenges from multiple stakeholders, and in response the SEC issued a stay in April 2024, effectively pausing implementation of the rule, pending judicial review. Most recently, in May 2026, the SEC submitted a proposal to the Office of Information and Regulatory Affairs to rescind the rule.

While most companies began prioritizing other sustainability regulatory requirements after the stay in the SEC’s climate rule, compliance with existing disclosure requirements under Reg S-K remains important and can result in climate-related disclosure being required.

Read our Defining Issues to help refresh your understanding of the 2010 SEC disclosure guidance, which outlines how existing Reg S-K disclosure obligations may apply to climate-related matters.

Source and applicability
Fast facts, impacts, actions
Evolution of SEC climate related disclosure
Relevant SEC reporting requirements
Potential effect of disclosure requirements
Materiality
Foreign Private Issuers

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