The SEC’s proposed rules are the culmination of activities that began in February 2021 when then-Acting SEC Chair, Allison Herren Lee, released a statement that she was directing the SEC’s Division of Corporation Finance to enhance its focus on climate-related disclosures in public company filings. In March 2021, the SEC requested public input on climate-related disclosures to help evaluate current rules. The comment period closed in June 2021, with SEC Chair Gary Gensler reporting that of the 550 unique comment letters received, 75% supported mandatory climate disclosure rules.
SEC Release Nos. 33-11042 and 34-94478
Assuming an effective date of December 2022 for the final rule and a registrant with a December 31 year-end:
Disclosures excluding Scope 3 disclosure | Scope 3 disclosure | |
Large accelerated filer | Fiscal 2023 | Fiscal 2024 |
Accelerated and non-accelerated filers | Fiscal 2024 | Fiscal 2025 |
Smaller reporting companies | Fiscal 2025 | Exempt |
Assuming an effective date of December 2022 for the final rule and a registrant with a December 31 year-end:
Scope 1 and 2 disclosure | Limited assurance thereon | Reasonable assurance thereon | |
Large accelerated filer | Fiscal 2023 | Fiscal 2024 | Fiscal 2026 |
Accelerated filer | Fiscal 2024 | Fiscal 2025 | Fiscal 2027 |
— Scott Flynn, KPMG US Audit Vice Chair
The proposed rules are intended to provide more consistent, comparable and reliable information so that investors can better evaluate the impact of climate-related matters on a registrant.
Financial statement disclosures would include:
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Greenhouse Gas (GHG) emissions disclosures would include:
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Other disclosures would include:
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Proposed applicability
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Background
Qualitative and quantitative disclosures
Example qualitative disclosures:
Example quantitative disclosures:
Location and timing of disclosures
Assurance
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