SEC Climate Disclosure: Your Roadmap to Compliance

In March 2024, the U.S. Securities and Exchange Commission (SEC) finalized its climate disclosure rule to enhance and standardize climate-related reporting for investors. The rule mandates that SEC registrants include specific climate-related information in their registration statements and periodic reports, such as the Form 10-K. This aims to create more transparent and comparable data across companies.

The required disclosures provide insight into a company's climate strategy and financial health. Key information includes:

• climate-related risks and their probable or actual material impacts on the registrant's company, strategy, and outlook
• registrant governance or risks and corresponding risk management processes
• greenhouse gas (GHG) emissions
• climate-related financial statement metrics
• climate impact targets, goals, and transition plans, if any

The SEC climate disclosure rule aligns with established frameworks like the Task Force on Climate-related Financial Disclosures (TCFD), pushing companies toward net-zero practices. It is a regulatory effort to support the goals of the Paris Agreement by giving investors clear visibility into corporate climate policies and impacts.

Tip: For a deeper understanding of GHG emissions, don’t miss our insights on the GHG Protocol, Product Carbon Footprint (PCF), Scope 3.1.

The SEC climate disclosure rule focuses on several core elements that companies must address in their reporting. Understanding them is the first step toward building a compliant disclosure strategy.

1. Materiality: Materiality is the threshold for disclosure. Companies must report on climate-related risks and events that have had or are reasonably likely to have a material impact on their business or financial condition. This includes the financial effects of events like wildfires, hurricanes, and floods.
2. Physical Risk: This element requires companies to disclose the potential physical risks of climate change on their assets and operations. This is divided into acute risks, which are event-driven (e.g., hurricanes), and chronic risks, which relate to longer-term shifts in climate patterns (e.g., rising sea levels).

3. Transition Risk: Companies must report on the risks associated with transitioning to a lower-carbon economy. This includes potential impacts from policy changes, new regulations, technological shifts, and changing market preferences that could affect a company's business model, operations, or financial standing.

4. Risk Management: This requirement involves detailing the company's processes for identifying, assessing, and managing its climate-related risks. The disclosure must explain how these processes are integrated into the company's overall risk management framework, demonstrating a proactive approach to mitigating climate threats.

5. Governance: Transparency around governance is crucial. Companies need to describe the board of directors' oversight of climate-related risks and management's role in assessing and managing those risks. This provides investors with insight into the level of accountability within the organization.

Adhering to the SEC climate disclosure requirements offers more than just regulatory compliance; it provides strategic advantages that can strengthen a company's market position and operational resilience.

Improved Risk Management and Decision-Making

The process of gathering data for compliance forces companies to deeply analyze climate-related risks and energy efficiency. This leads to better internal risk management strategies and more informed decision-making, which can protect against future threats while improving operational efficiency and reducing costs.

Increased Transparency and Credibility

By publicly disclosing climate risk management actions through the SEC, companies provide transparency and accountability. This builds credibility with stakeholders, including customers, employees, and the public. You are not just claiming to be sustainable; you are demonstrating it with verified data.

Enhanced Investor Confidence

Climate-conscious investors are increasingly looking for companies that are transparent about and actively managing climate-related risks. Compliant disclosures enhance a brand's reputation, build trust, and can help attract capital from a growing pool of ESG-focused investors.

Navigating SEC’s climate disclosure requirements can be complex. To ensure accurate and compliant reporting, it is essential to avoid these common mistakes.

Underestimating Materiality: A narrow view of materiality can lead to legal and financial risks. Companies must conduct a thorough assessment of all potential climate-related risks across their value chain to avoid overlooking information they are legally required to disclose. Working with a professional advisor can ensure a comprehensive review.

Inadequate Disclosure: Simply stating a commitment to risk management is not enough. Adequate disclosure requires demonstrating this commitment with a detailed plan. Companies must follow through by clearly outlining how they identify, assess, and plan to manage the specific climate risks they have identified.

Lack of Consistency in Reporting: Climate disclosure is an ongoing process, not a one-time report. Companies must consistently document their progress toward climate-related goals over time. Using standardized frameworks ensures that reporting is objective, comparable, and provides a clear benchmark for stakeholders to track performance annually.

Complying with the SEC climate disclosure guidance is a complex but necessary process. Automating data collection and analysis with a dedicated carbon management platform can streamline your efforts and ensure accuracy.

carbmee EIS™ empowers you to effectively manage and mitigate climate-related risks. 

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Which Companies Are Required to Comply With the SEC Climate Disclosure Rule?

Companies required to comply with the SEC’s climate disclosure rule include Large Accelerated Filers (LAFs) and Accelerated Filers (AFs). These companies must disclose Scope 1 and Scope 2 greenhouse gas emissions, as well as material climate-related financial risks, following TCFD-aligned standards. Scope 3 emissions are only required if they are financially material or if the company has publicly committed to Scope 3 targets. Smaller companies are exempt from these requirements.

What Is the Current Status of the SEC Climate Disclosure Rule?

As of late 2025, the SEC climate disclosure proposal is on hold. Although adopted in March 2024, it was quickly challenged in court and placed under a voluntary stay. In March 2025, the SEC withdrew its defense of the rule, and in September, the Eighth Circuit paused the case indefinitely unless the SEC chooses to revisit or defend it. While the rule’s future remains uncertain at the federal level, climate disclosure regulations are moving ahead in several U.S. states, and internationally through frameworks like the EU’s CSRD and the ISSB standards.

What Was the Proposed Timeline for the SEC Climate Disclosure Rule?

If implemented as planned, the rule would have followed a phased timeline. Large Accelerated Filers (LAFs) were expected to start collecting data in 2025, disclose climate-related risks in 2026, and begin reporting Scope 1 and 2 emissions in 2027. Smaller companies would have followed with later deadlines.