Divergent Rules: Climate Disclosure in a Fragmenting Regulatory Landscape

The pullback of SEC climate disclosure rules, combined with accelerating state action and evolving EU policies, is reshaping how companies assess and manage climate-related disclosure risk.

Why This Report Matters

Climate disclosure requirements are entering a period of transition. As the SEC steps back from enhanced climate reporting rules, regulatory pressure hasn’t eased. Instead, it’s shifting to other regulators, creating a more complex and fragmented disclosure environment for SEC registrants.

This report examines how recent regulatory developments are reshaping climate disclosure risk, with a focus on the SEC’s reversal on climate disclosure rules, the emergence of state-level mandates and evolving EU disclosure regimes that could create significant compliance challenges for U.S. companies within their scope.

Key Insights

Some of the key topics covered include:

• The SEC’s retreat from climate disclosure requirements and its broader deregulatory agenda
• State and EU climate disclosure regimes that continue to shape disclosure risks for SEC registrants
• Early signals from public company risk factor disclosures reflecting these regulatory shifts

Best Suited For

This report is designed for professionals responsible for meeting climate-related obligations across multiple jurisdictions, including state-level mandates and EU regulations:

• Legal and compliance teams
• Finance and SEC reporting professionals
• Corporate risk and strategy leaders