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Overview of the Rules
Under Regulation S-K and S-X, the adopted SEC rules require public company registrants to disclose both qualitative and quantitative climate related information in registration statements, Exchange Act reports and consolidated financial statements (e.g., Form 10-K, Form 10Q), and electronically tagged using Inline XBRL. In-scope companies will be required to disclose material climate-related risks to their business and operations, board and management oversight over such risks, information on material climate-related targets or goals, and details on material greenhouse gas (GHG) emissions for certain in-scope companies. In addition, independent attestation will be required around GHG disclosures for companies required to report on their carbon emissions. The final rules include a phased-in, proportionate timeline for all U.S. public registrants to comply with the disclosure requirements.
Applicability Timeline
The SEC’s final rules phase in for registrants to report for the following fiscal years:
Registrant
Type
Financial
Statements &
Climate Risk
Disclosures
Material
Expenditure
Footnote
Disclosures
GHG Emissions
Disclosures
Limited Assurance
of GHG Disclosures
Reasonable
Assurance of GHG
Disclosures
Inline XBRL
Electronic Tagging
Large
Accelerated
Filers
FY2025
FY2026
FY2026
FY2029
FY2033
FY2026
Accelerated
Filers
FY2026
FY2027
FY2028
FY2031
N/A
FY2026
Smaller Reporting
Companies
Emerging Growth
Companies
Non Accelerated
Filers
FY2027
FY2028
N/A
N/A
N/A
FY2027
US SEC Climate Disclosure Rules
The Way Forward
Build understanding around the TCFD framework elements
01
Leverage a phased approach to prioritize disclosure requirements
02
Collaborate crossfunctionally to improve reporting process
03
Leverage technology for data management and build capacity
04
Prepare for independent assurance if applicable