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ARTICLE · 24 MARCH 2022

SEC's Climate Proposal—SCOOP!

According to exclusive reporting from Bloomberg, the SEC's new proposal for climate disclosure regulation—scheduled for a vote and release on Monday—will include a requirement to disclose some Scope 3 emissions...

United StatesCorporate/Commercial Law

According to exclusive reporting from Bloomberg, the SEC's new proposal for climate disclosure regulation—scheduled for a vote and release on Monday—will include a requirement to disclose some Scope 3 emissions,  that is "greenhouse gases that are generated by other firms in [a company's] supply chain or by customers using [its] products."  It's widely believed that Scope 3 emissions "make up the bulk" of most companies' emissions.  It's unclear whether the proposed requirement would apply to all public companies or just larger ones, or whether the requirement might be phased in. As discussed below, whether or not to require disclosure of Scope 3 emissions has been a subject of heated internal debate at the SEC, and, the article suggests, the proposal appears to reflect some compromise.

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