Defining Issues | March 2021



SEC to focus on climate-related disclosures

KPMG reports on this latest SEC development: the disclosure requirements, and implications and actions for management.

Timothy Brown

Timothy Brown

Partner, Dept. of Professional Practice, KPMG US

+1 212-954-8856

Maura Hodge

Maura Hodge

Partner, KPMG IMPACT Audit Leader, KPMG US

+1 803-606-8370

ESG (Environmental, Social, Governance) is playing an increasingly important role in the strategy and operations of companies, and investment decisions are increasingly being driven by ESG metrics. Here we report on SEC developments.


Statement by Acting SEC Chair, Allison Herren Lee

  • Public companies, including foreign filers

Focus on ESG

1 in 4

US Fortune 100 companies reports climate risk in line with Task Force on Climate-Related Financial Disclosures


of US Fortune 100 companies now acknowledge the financial risks of climate change in their reporting


of US Fortune 100 companies now have targets in place to reduce their carbon emissions

A majority

of US Fortune 100 companies (71%) that report carbon reduction targets now link those targets to global climate goals

Source: US company results as part of the KPMG Survey of Sustainability Reporting 2020; survey of 5,200 companies globally, including 208 in the United States. 
Access the full survey here.

Relevant dates

  • Effective immediately
  • Comments in response to the SEC’s request for public input on climate-related disclosures are due by June 13, 2021.

Key impacts

  • On March 15, 2021, Acting SEC Chair Allison Lee continued the recent focus on climate-related disclosures in a statement requesting public comments on a series of questions.  The SEC staff will consider this information in their evaluation of current climate change disclosure rules and guidance and to facilitate future rulemaking activity in this area.
  • On February 24, 2021, Acting SEC Chair, Allison Herren Lee, released a statement that she is directing the SEC’s Division of Corporation Finance to enhance its focus on climate-related disclosures in public company filings.
  • Lee’s statement was followed by inclusion of the topic in the SEC’s 2021 examination priorities, and the formation of a Climate and ESG Taskforce in the Division of Enforcement.
  • Efforts will be directed at evaluating compliance with existing disclosure guidance that was issued in 2010 and developing insights to help modernize that guidance. 
  • The specific actions may evolve over time and could range from review and analysis of existing disclosures to inform future rulemaking, to the issuance of comment letters to registrants regarding compliance with the 2010 disclosure guidance.
  • The SEC’s announcement is a call to action for registrants to refresh their understanding of the 2010 disclosure guidance – which explains how the Regulation S-K requirements apply to climate-related matters – and to carefully analyze the quality of their disclosures.
  • Consistent with the most recent amendments to Regulation S-K, these disclosures should provide investors with a view of the registrant through the eyes of management. 


Report contents

  • Fast facts, impacts, actions
  • Background to the SEC announcement
  • ESG landscape and SEC filing implications
  • Refresh: current SEC reporting requirements
  • Potential impact of disclosure requirements
  • Reminder: through the eyes of management
  • Recap: what is ESG and why is it important?

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