Comments to the US SEC Consultation on Disclosure

July 6, 2022

The US finance regulator U.S. Securities and Exchange Commission has proposed to make climate risk disclosure mandatory for listed US and foreign firms. We participated in their open consultation with two comments to share our support for the proposal and give our recommendations.

Why is this proposal so crucial? It would a) significantly increase transparency about material climate risks of high relevance for any investor in US equities b) help companies understand climate risks along the entire EU-US supply chains; and c) help generate an international level playing field across different mandatory sustainability reporting mechanisms (EU, G20).

In the first more general comment (co-signed by other experts in the field), we set out eight recommendations to help improve the effectiveness and comparability of this important initiative. You can read and download our general comment here.

In the second and more in-depth comment, we provided technical inputs on a subset of questions that were part of the proposed regulation. We answered some of the SEC’s questions based on our policy expertise, our close cooperation with reporting entities (in particular corporates) and users of disclosures (in particular financial institutions and regulators). You can read and download our in-depth comment here.