Coming to Terms with the SEC’s Proposed Climate Disclosure Rule

On March 21st, Francesca Odell and Nick Grabar, Partners, and Shuangjun Wang, Senior Associate, from Cleary Gottlieb Steen & Hamilton provided a briefing for ESG Center members on the SEC’s proposed climate-related disclosure rule. They began with an overview of the three main components of the proposed rule: (1) the new “climate-related disclosure” section of Annual Reports on Form 10-K and 20-F, including (2) emissions disclosures and the related attestation report, and (3) new disclosures in the notes to the audited financial statements. The briefing yielded several key takeaways, including the following:

• Don’t panic, but do prepare. Many companies have been providing significant climate-related di