SEC Voluntarily Stays Final Rule On Climate Disclosures

On April 4, 2024, the U.S. Securities and Exchange Commission (SEC) issued an order staying the Final Rule for the Enhancement and Standardization of Climate-Related Disclosures for Investors ("Final Rule") that it released not more than a month before, to require registrants to provide certain climate-related disclosures in their registration statements and annual reports.¹ The SEC's administrative stay will remain in place until the completion of litigation filed in the federal courts that challenges the agency's authority to adopt the Final Rule.

We previously provided an update on the Final Rule, which was finalized on March 6, 2024, and we noted the staggered compliance dates, which began as early as 2025 and as late as 2033, depending on the registrant's filing status and the type of disclosure. The stay is likely to affect these dates, given the likelihood that it will still be in place by the time — in 2025 — that the first registrants would be required to