Climate Disclosure Update
Pencils down on climate disclosure compliance? Not so fast. It is uncertain when or if the SEC’s new climate disclosure rules will come into effect. The ultimate fate of the rules is unclear given the litigation over the rules in the Eighth Circuit. In addition, the SEC recently stayed the rules pending resolution of the […]
Michael Littenberg is a Partner and Global Head of ESG, CSR and Business and Human Rights Practice, and Marc Rotter is Counsel at Ropes & Gray LLP.
Pencils down on climate disclosure compliance? Not so fast.
It is uncertain when or if the SEC’s new climate disclosure rules will come into effect. The ultimate fate of the rules is unclear given the litigation over the rules in the Eighth Circuit. In addition, the SEC recently stayed the rules pending resolution of the litigation. However, as we have said before, “it’s not pencils down on climate disclosure more generally.” Public and private companies need to manage to other current and pending climate disclosure requirements (and other ESG disclosures more generally) at the U.S. federal and state levels as well as outside the United States. As discussed in this piece, even though the SEC’s new climate disclosure rules are on hold and may be scaled back or never implemented, there are other climate disclosure requirements to take into account.
