Quarles & Brady: SEC Proposes Extensive Climate Change Reporting Obligations for Public Companies

On March 21, 2022, the Securities and Exchange Commission (SEC) proposed its long-awaited rules requiring more robust climate change disclosures for publicly traded companies. The reach of these proposed rules is extremely broad – addressing not only a company’s carbon footprint, but also its short-, medium-, and long-term plans related to climate change and its assessment of how the world’s changing climate will affect its operations and value. For some companies, the proposed rule would also mandate discussion of greenhouse gas (GHG) impacts of their supply chains and their customers use of their products. In short, if finalized, the SEC’s proposed regulations would completely overhaul the climate change disclosure obligations of public companies and create a new level of accountability and transparency related to sustainability reporting.

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