The long-awaited rules, already at the center of political debate and litigation, represent another global regulatory effort to integrate climate considerations into financial reporting.

On March 6, 2024, nearly two years after its proposed rules were first released, the US Securities and Exchange Commission (the SEC or the Commission), in a 3-2 vote along party lines, approved final rules requiring companies to disclose certain climate-related information in registration statements and annual reports. The final rules are already the focus of litigation, with a number of parties on both sides of the policy debate filing petitions for review across the country. On March 15, 2024, the US Court of Appeals for the Fifth Circuit granted an administrative stay of the final rules in response to a request for review, as discussed in more detail in our blog post. As a result of the administrative stay and in light of additional pending legal challenges, the timing of effectiveness of the final rules and applicable phase-in periods, as well as whether any portions of the rules are likely to remain in effect after the litigation, are all highly uncertain.