On April 4, 2024, the SEC issued a stay of its final
climate-related disclosure rules. The SEC adopted the long-awaited
final rules in March after receiving more than 24,000 comment
letters. WilmerHale's summary and analysis of the final rules
can be found on the
Keeping Current: Disclosure and Governance Developments
blog.
While the final rules were scaled back in many respects from the
proposed rules, several entities and states filed a flurry of
petitions in multiple circuit courts of appeal. In total, nine
petitions were filed in six circuit courts of appeal. On March 15,
2024, the U.S. Court of Appeals for the Fifth Circuit granted a
motion filed by two petitioners seeking an administrative stay of
the final rules.