SEC Climate-Related Disclosures
Current understanding
The SEC’s 2024 rules required public registrants to disclose climate-related risks, governance, targets, and certain GHG emissions (Scopes 1 and 2 for larger filers) in registration statements and periodic reports. The rules were stayed amid litigation and, in 2025, the SEC proposed to rescind them, arguing they exceed the agency’s disclosure mandate and impose disproportionate compliance costs; proponents counter that investors rely on standardized climate risk data. Status: proposed rescission (proposed rule).
Evidence log
- 2025-11-18 — Climate Solutions Act of 2025: cross-connection with climate-solutions-act-2025: A statutory net-zero-by-2050 trajectory with annual EPA GHG targets would materially change the baseline against which SEC climate-related disclosures (currently proposed for rescission) would be evaluated by registrants. (novelty: 3)
- 2026-05-07 — Defense Federal Acquisition Regulation Supplement: Disclosure of Greenhouse Gas Emissions (DFARS Case 2024-D021): cross-connection with federal-contractor-ghg-disclosure: Both establish mandatory GHG emissions disclosure regimes on different populations (federal contractors via DFARS/FAR vs. SEC registrants); together they define the federal government’s split approach to emissions transparency across procurement and securities law. (novelty: 2)
- 2025-03-26 — ESG Act of 2025: cross-connection with esg-investment-advice-fiduciary-standard: Both actions constrain how climate/ESG information flows through securities markets — SEC rescission removes issuer-side climate disclosure obligations while the ESG Act constrains adviser-side use of ESG factors in retail investment recommendations. (novelty: 3)
- 2026-06-03 — Rescission of Climate-Related Disclosure Rules: cross-connection with methane-waste-emissions-charge: Both bear on federal accounting for GHG emissions from regulated entities; rescission of SEC disclosure and CRA rollback of the methane fee together reduce federal-level emissions reporting/pricing obligations on the oil & gas sector. (novelty: 3)