SEC Climate Disclosure Rule — Climate-Related Disclosures for Investors

The U.S. Securities and Exchange Commission adopted its final climate-related disclosure rule in March 2024, which would have required SEC-registered public companies to disclose material climate-related risks, governance processes, Scope 1 and Scope 2 greenhouse gas emissions, and certain Scope 3 emissions. The rule represented the most significant federal expansion of corporate climate disclosure requirements in U.S. history.

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The SEC issued a voluntary stay of the rule in April 2024 pending litigation. In March 2025, the Commission announced it would no longer defend the rule in court, effectively withdrawing federal support for its implementation. The Eighth Circuit has placed the litigation in stasis pending further agency action. SEC Chair Paul Atkins has indicated no intention to revive or defend the rule under the current administration.

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The federal retreat from mandatory climate disclosure has increased the strategic importance of state-level requirements, particularly in California, and of voluntary frameworks such as ISSB, TCFD, and CDP. Institutional investors, lenders, and large corporate customers have not pulled back their climate data requests in line with the SEC's position — demand for emissions data and climate risk disclosure from the private sector continues to grow regardless of regulatory status.

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Public companies are not relieved of disclosure obligations altogether. Material climate risks must still be disclosed under existing SEC materiality standards in 10-K filings. The rule's withdrawal changes the form and specificity of required disclosures, not the underlying obligation to disclose material risks.