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ARTICLE · 14 MARCH 2024

Early Note On SEC's Final Climate Rules: Governance, Materiality And Dissent

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The Securities and Exchange Commission adopted (in a 3-2 vote) final rules requiring disclosures about the material impacts of climate-related risks on their business, financial condition, and governance.

United StatesCorporate/Commercial Law
Anna T. Pinedo
Anna T. Pinedo
Lawrence A. Cunningham
Lawrence A. Cunningham
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The Securities and Exchange Commission adopted (in a 3-2 vote) final rules requiring disclosures about the material impacts of climate-related risks on their business, financial condition, and governance.

These rules had first been proposed in March 2022. The SEC adopted the final rules after considering, over a two-year period, some 4,500 unique comment letters from various authors. The SEC made some modifications from the Proposed Rules, most conspicuously withdrawing disclosure of greenhouse emissions from the users of a company's products and services (so-called Scope 3 emissions).

The SEC observes that many companies currently disclose substantial climate related information but characterizes this disclosure as "partial," "fragmented," "inconsistent" and "often difficult for investors to find and/or compare across companies." The SEC says that its experience with its existing climate disclosure guidelines, in effect since 2010, indicates inadequate

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This Mayer Brown article provides information and comments on legal issues and developments of interest. The foregoing is not a comprehensive treatment of the subject matter covered and is not intended to provide legal advice. Readers should seek specific legal advice before taking any action with respect to the matters discussed herein.

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