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Mandatory from 2025SEC Climate Disclosure Rules
In March 2024, the SEC adopted rules requiring listed companies to disclose material climate risks, governance and risk-management processes, and, by larger filers, Scope 1 and 2 GHG emissions with phased assurance. The rule is stayed pending litigation, and the SEC has since stepped back from defending it. Investors should note the framework remains influential in shaping U.S. market practice, despite uncertain enforcement.
Key Requirements
- •Governance, oversight and management of material climate risks
- •Impacts on business model, strategy, and outlook
- •Disclosure of targets, transition plans, scenario analysis or internal carbon pricing if used
- •GHG emissions: Scope 1 and 2 (when material) for large filers, with phased assurance; Scope 3 excluded
- •Financial-statement notes on weather-related impacts and offsets/RECs
Implementation Timeline
Paused. (All dates stayed pending court outcome.)
Large accelerated filers: Non-emissions disclosures from FYB 2025; GHG from FYB 2026; limited assurance FYB 2029; reasonable assurance FYB 2033
Accelerated filers: Non-emissions FYB 2026; GHG FYB 2028; limited assurance FYB 2031
Smaller/EGCs: Non-emissions FYB 2027; exempt from GHG
Report Timing
In annual reports (10-K/20-F) and registration statements. GHG data may be filed later (Q2 for domestic, 20-F amendment for FPIs).
Compliance Status
Mandatory from 2025Track your progress towards meeting the requirements and deadlines for this regulation.