• The Securities and Exchange Commission today proposed a much-anticipated set of requirements for public companies to disclose information about climate risks affecting them, their greenhouse gas footprints and any emissions-reduction plans they may have adopted.
• SRCs would be exempt entirely from scope 3 disclosures, and due to their complexity scope 3 disclosures would phase in after scope 1 and 2 for larger registrants and also be subject to a safe harbor.
• Under the proposal, SEC registrants’ registration statements and periodic reports like Form 10-K would be required to disclose: how their boards and managers are overseeing climate-related risks; the material effects of climate-related risks on business plans, strategies and financial statements over various terms; how companies identify and manage climate-related risks; and any transition plans, scenario analyses or internal carbon pricing used by the registrant.

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