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 May 2026, the SEC proposed to rescind its climate rule in its entirety. The rule was originally adopted in March 2024 but was quickly met with legal challenges from multiple stakeholders, prompting the SEC to issue a stay in April 2024 that remains in effect and has effectively paused 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.

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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