SEC disclosure guidance on climate-related risks remains
DEFINING ISSUES | AUGUST 2025
Companies should continue to focus on existing SEC climate-related disclosure guidance.
Applicability
SEC Release Nos. 33-9106; 34-61469
Commission Guidance Regarding Disclosure Related to Climate Change
- Public companies, including foreign filers
Key Impacts:
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.
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.
Report contents
- 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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