SEC Proposes Broad New Climate Change Disclosure Requirements

In a 500-page release, the SEC has proposed significant new public company climate change disclosure requirements for both domestic companies and foreign private issuers, including the actual and potential impacts of climate change on companies as well as management and governance processes to address those impacts. The proposed disclosure rules among other things would amend Regulation S-K to add a new section to companies' filings, including third-party attestation requirements for greenhouse gas emissions data. The proposals would also amend Regulation S-X to add new financial statement requirements. The proposed disclosures are loosely based on existing metrics that many companies already apply, at least in part, particularly those of the Task Force on Climate-Related Financial Disclosures (TCFD) and the Greenhouse Gas Protocol.