In another step toward the integration of climate factors into the US corporate disclosure landscape, Acting Chair of the US Securities and Exchange Commission (SEC), Allison Herren Lee, issued a request for public input on climate change disclosures on March 15, 2021.

The request seeks input relating to 15 climate-related disclosure topics, including:

  • specific disclosure metrics that may be used to quantify climate information, including GHG emissions in line with the GHG Protocol and GHG reduction goals;
  • the advantages and disadvantages of existing disclosure frameworks (specifically referring to the TCFD, SASB and CDSB frameworks);
  • whether climate disclosure requirements should be incorporated into existing rules, like Regulation S-K, or new regulations; and
  • the advantages and disadvantages of a “comply or explain” framework.

The variety and scope of topics suggests that the SEC is considering a broad range of approaches to climate-related disclosure. The request also suggests that other ESG-related disclosures may follow, noting that “the staff is evaluating a range of disclosure issues under the heading of environmental, social, and governance, or ESG, matters.”

The SEC provides a webform and email box for the public to provide input on these issues, and asks for comments within 90 days. For more information on the SEC’s ESG efforts, including the recent creation of its Climate and ESG Task Force, see our earlier Blog Post here.

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