United States: SEC (Securities and Exchange Commission)

Climate-related financial disclosures for US-listed companies.
Status: 2024 rules stayed in 2025 pending litigation; financial materiality approach.
Coverage
~7,000
US-listed companies (2025)[9]
Materiality Standard
Financial
Disclosure only if material to investors[1][5][9]
Scope 1 & 2 Emissions
Required*
Large accelerated filers, phased in 2026–2028[1][4][5]
Scope 3 Emissions
Voluntary
Recommended if material or target-linked[1][4][5]
SEC Climate Disclosure Rule: Key Requirements
DimensionDescriptionRequired?
GovernanceBoard and management oversight of climate risksYes
Risk ManagementIdentification, assessment, and management of material climate risksYes
StrategyMaterial impacts of climate risks on business model and financialsYes
Emissions ReportingScope 1 & 2 GHG emissions (large filers); Scope 3 if material or target-linkedYes*
Financial Statement ImpactsMaterial climate-related effects on consolidated financialsYes
AssuranceThird-party limited assurance (Scope 1 & 2, phased); reasonable assurance by 2030Yes*
* Scope 1 & 2 phased, Scope 3 voluntary; rule stayed pending litigation as of April 2025[1][2][3][5][6][7][8]
SEC Climate Rule Timeline and Status
YearMilestoneStatus (2025)
2022Rule proposed: “Enhancement and Standardization of Climate-Related Disclosures”Finalized in 2024
2024Rule adopted (March); immediate legal challenges, voluntary stay issued (April)Stayed, not in effect[1][2][3][5][6][7][8]
2025SEC ends defense of rule in court (March 27)Litigation ongoing; implementation uncertain[2][3][6][7][8]
2026–2028Phased compliance for Scope 1 & 2 (if rule survives)Uncertain
SEC Climate Rule: Coverage by Company Type
Estimated number of US-listed companies by filer type (2025)[9].
SEC Integration and Influence
  • Materiality: Financial materiality standard (US Supreme Court definition)[1][5][9]
  • Alignment: TCFD structure, GHG Protocol, ISSB climate disclosure[4][5][9]
  • Assurance: Third-party limited assurance (Scope 1 & 2), reasonable by 2030[1][5]
  • Legal status: Rule stayed, enforcement paused pending litigation as of April 2025[2][3][6][7][8]
  • Comparison: Narrower than EU CSRD (no double materiality, Scope 3 voluntary)[9]

About the SEC Climate Disclosure Rule

The SEC’s 2024 climate disclosure rule, now stayed pending litigation, would require all US-listed companies to disclose material climate-related risks, governance, risk management, strategy, and Scope 1 & 2 GHG emissions (Scope 3 voluntary)[1][2][3][4][5][6][7][8][9]. The rule is built on financial materiality and TCFD alignment, with phased assurance and integration into Regulation S-K and S-X. Its legal fate remains uncertain, but climate-related risk is now embedded in US securities law and investor expectations.

Note: All data reflects official SEC, legal, and industry updates as of May 2025.

United States - SEC (Securities and Exchange Commission)