The U.S. Securities and Exchange Commission adopted the SEC Climate Disclosure in 2024 to change how publicly traded companies report their climate-related risks and greenhouse gas emissions. But the rules never took effect: the SEC stayed them in April 2024 amid legal challenges, voted to stop defending them in court in March 2025, and formally proposed rescinding them on May 29, 2026. Barring a reversal, U.S. public companies will not face an SEC climate disclosure mandate.
Then-SEC Chair Gary Gensler highlighted the significance of consistent climate information for investors saying the rules would
“provide investors with consistent, comparable, and decision-useful information, and issuers with clear reporting requirements.”
Had they taken effect, the rules would have required companies to add climate-related information to their annual reports. They drew on frameworks that remain very much alive for U.S. companies, including the European Union’s Corporate Sustainability Reporting Directive (CSRD).
To help you navigate this shifting compliance space, we’re covering what the SEC Climate Disclosure rules would have required, where they stand now, and which climate disclosure requirements still apply.
What was SEC Climate Disclosure?
The SEC Climate Disclosure was adopted as a set of rules for publicly traded companies. They would have had to disclose both how climate risks impact their financial performance and what impact climate change scenarios could have on the performance of their business.
This dual approach went beyond simply reporting greenhouse gas emissions (Scope 1 and 2 — the final rules dropped Scope 3). It urged organizations to share how they’re preparing to respond to climate risks including severe weather events or the influence of a low-carbon economy.
Who would have had to comply with SEC Climate Disclosure rules?
The SEC Climate Disclosure rules would have applied to publicly traded companies in the United States, particularly large accelerated filers (i.e. companies with a public float of $700 million or more). Smaller accelerated filers and other public companies would have faced similar requirements over time but with staggered deadlines.
Private companies were never in scope — and with the rules stayed and pending rescission, no company currently has to comply. You should still track and report your climate data for investors, stakeholders, and future directives. Mandatory disclosure requirements do still apply regionally within the U.S. — most notably in California, where SB 253 has first reports due in November 2026; companion law SB 261 is currently under a court-ordered enforcement pause. Similarly, regulations such as the Corporate Sustainability Due Diligence Directive (CSDDD) apply in the EU with their own (yet similar) requirements for climate-related reporting.
Verena Radulovic, Vice President for Business Engagement at the Center for Climate and Energy Solutions, suggested that while the SEC rules may seem less stringent than those in the EU, companies reporting to both frameworks may find that the overlaps reduce the additional reporting burden:
“Large public companies have been reporting on sustainability and climate for a long time — at least two decades for greenhouse gas inventories in some cases. According to one estimate, 94% of the S&P is already reporting on climate performance. Many talented people are already working on engaging internal stakeholders, generating shareholder value, and mitigating risks, which should ostensibly reduce reporting burden.”
Next is a complete breakdown of when different company types would have started reporting.
SEC Climate Disclosure timeline
As adopted, the compliance timeline would have started with fiscal years beginning in 2025. Their Scope 1 and Scope 2 greenhouse gas emissions disclosures, where material, would have followed from fiscal years beginning in 2026. Here’s how it was set to phase in before the stay:
The first reports would have covered climate-related disclosures alone, applying to large accelerated filers with a public float of at least $700 million from fiscal years beginning in 2025. Their Scope 1 and Scope 2 greenhouse gas emissions disclosures, where material, would have followed from fiscal years beginning in 2026 — along with how they plan to tackle climate-related risks and what financial planning looks like in those scenarios.
Accelerated filers with a public float of $75 million to $700 million would have followed, with climate disclosures from fiscal years beginning in 2026 and emissions reporting from 2028. Covered companies would have added financial statement disclosures showing the impact of climate-related risks on their financial health.
A note on Scope 3: unlike the 2022 proposal, the final rules dropped Scope 3 reporting entirely, even for emissions seen as material to the business or covered by emission reduction targets.
Attestation would have phased in last. Large accelerated filers would have needed limited assurance over their Scope 1 and Scope 2 emissions from fiscal years beginning in 2029, stepping up to reasonable assurance from 2033, to prove disclosure accuracy.
Accelerated filers would have followed with limited assurance from fiscal years beginning in 2031; smaller reporting companies were exempt from emissions reporting altogether.
How to prepare for the climate disclosure rules that still apply
The SEC rule may be shelved, but California’s SB 253 and SB 261, the EU’s CSRD, and voluntary frameworks reward the same readiness. You can follow a structured approach to cover it all.
Step 1: Gathering your climate data
The first step for any climate disclosure rule is collecting data on your greenhouse gas emissions, water and energy consumption, as well as other factors that might be impacting the environment during your business operations.
Step 2: Analyzing your climate risks
A risk assessment helps you identify both physical and transitional risks related to climate change that could affect your business operations. At this stage, focus on prioritizing risks by considering both the severity of their impact and the likelihood of them occurring.
Step 3: Discuss your climate-related goals and plans
Focus on what’s next by setting clear, measurable objectives focused on reducing greenhouse gas emissions, enhancing energy efficiency, and promoting sustainable supply chain practices.
You must then create a step-by-step action plan to cover timelines, responsible parties, and resources needed to achieve these goals, considering their potential impact on financial projections.
Tanya Nesbitt, Partner at Thompson Hine, emphasizes how organizations are required to disclose any mitigation activities undertaken:
“If a company has undertaken activities to mitigate or adapt to climate-related risks, they’ll have to disclose that in the form of a quantitative or qualitative description of any material expenditures incurred and any material impacts on their financial estimates and assumptions that resulted from the mitigation.”
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