On February 28, 2024, the U.S. Securities and Exchange Commission (SEC) published notice of an open meeting to be held on Wednesday, March 6, 2024, to consider whether to adopt rules to require public companies to disclose certain climate-related information in their registration statements and annual reports.

The SEC proposed climate change disclosure rules in March 2022, which were modeled in part on the Task Force on Climate-Related Financial Disclosures and the GHG Protocol. For information on the proposed rules, please see our Client Alert.

The proposed rules have been the subject of intense scrutiny, including thousands of public comment letters submitted to the SEC (available here), and speculation as to what the final rules may look like. As recently as last week, Reuters reported that the SEC was planning to drop the Scope 3 emissions disclosure from the final rules. We look forward to seeing how the final rules differ from the proposed rules and will issue a client alert on the final rules.