Reports, Submissions

Public Input to the SEC: Climate Change Disclosures

Turbulent sea with fishing boat and strom clouds in background. Photo by Wai Siew on Unsplash
Turbulent sea with fishing boat and strom clouds in background. Photo by Wai Siew on Unsplash.

E3G has submitted a response to a call for public input from the US Securities and Exchange Commission (SEC) on climate change disclosures.

The call for public input on the SEC’s ongoing work on climate change disclosure was a welcome opportunity to articulate the need for such regulation and what it should include to drive comparable and consistent climate change disclosure from companies. We additionally acknowledge the significance of the Executive Order on Climate-Related Financial Risk made by President Biden on May 20th, including its emphasis on advancing “consistent, clear, intelligible, comparable, and accurate disclosure of climate-related financial risk”.

In our response to the questions posed by the SEC, E3G recommends several key areas for the SEC to require mandatory disclosure from registrants on climate change.

Our recommendations include the following:

  1. Requiring registrants to disclose against the full 11 recommendations made the Taskforce for Climate-related Financial Disclosures.
  2. Mandating the disclosure of climate transition plans for net-zero by 2050, as part of disclosure on material climate-related risks and opportunities.
  3. Requiring registrants to disclose Scope 1, 2 & 3 emissions on a phased basis.
  4. Requiring registrants to disclose whether climate scenarios have informed their strategy and provide detail on these scenarios including underlying assumptions and alignment with a 1.5°C trajectory.

Read the response in full.


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