The SEC has extended the public comment period regarding its proposed “Enhancement and Standardization of Climate-Related Disclosures for Investors." The new deadline is June 17, 2022.

As outlined in our previous alerts – The SEC’s Proposed Climate-Risk Disclosure Rule – What You Need to Know Now and Deep Dive: GHG Reporting Under the SEC’s Proposed Climate-Related Disclosure Rule – the proposed rule would dramatically alter and expand the requirements for climate-related disclosures by publicly traded companies if approved.

Companies would be required to make disclosures regarding:

• The material climate-related risks to the company and its business strategy
• The governance and oversight processes in place at the board and management levels to identify and address climate-related risks
• The company’s disaggregated and aggregated greenhouse gas emissions including, for larger companies, disclosures about the greenhouse gas emissions of the company’s upstream and downstream supply chain partners if those emissions are material or if the company has set emission targets that include these emissions

Given the broad and potentially burdensome nature of the proposed rule, companies should give serious consideration to submitting public comments and responding to one or more of the 200 questions posed by the SEC. Alternatively, companies should consider working with a trade association to submit comments.

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