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The SEC unveils environmental disclosure requirements
Heads Up: SEC proposal for climate-related disclosures
Under the SEC’s proposed climate disclosure rule, companies must provide an accounting of their greenhouse gas (GHG) emissions, the environmental risks they face, and the measures they’re taking in response. Here are the key components along with how companies can assess their approach.
Background
On March 21, 2022, the SEC issued a proposed rule that would enhance and standardize the climate-related disclosures provided by public companies. As SEC Chair Gary Gensler noted in his statement about the proposed rule, “Today, investors representing literally tens of trillions of dollars support climate-related disclosures because they recognize that climate risks can pose significant financial risks to companies, and investors need reliable information about climate risks to make informed investment decisions.”
Under the proposed rule, a registrant would be required to provide disclosures about GHG emissions (with attestation for Scope 1 and Scope 2 disclosures), certain financial statement disclosures, and qualitative and governance disclosures within its registration statements and annual reports (e.g., Form 10-K). Comments on the proposed rule are due 30 days after its publication in the Federal Register or May 20, 2022, whichever is later.
Key components of the proposed climate disclosure requirements
In the proposing release, the SEC noted that the disclosures registrants would be required to provide are similar to those that many companies provide under existing disclosure frameworks and standards, such as the Financial Stability Board’s Task Force on Climate-related Financial Disclosures (TCFD) and the Greenhouse Gas Protocol. Registrants would be required to provide the following types of disclosures:
Questions to consider
Given the challenges expressed by respondents in a recent Deloitte survey, and in anticipation of the final rule, companies may wish to begin preparing now by using the proposed rule as a framework and by considering the following questions:
As noted above, the SEC has indicated that the proposed rule is consistent with existing frameworks or standards, such as those recommended by the TCFD and the GHG Protocol. Therefore, registrants that already provide such disclosures may be better positioned to implement the proposed rule’s requirements.
Continue your climate disclosure requirement learning
For a comprehensive analysis of the proposed rule, see Deloitte’s March 29, 2022, Heads Up.
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Laura McCraken
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Deloitte & Touche LLP
+1 212 653 5738
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