Gustavo Bernal Torres
SEC Issues Long-Awaited Climate Disclosure Proposal
After a year of pre-proposal development, drama and general anticipation, the SEC voted to issue its proposed rules on climate disclosures.
The proposal weighs in at 510 pages and is comprehensive. Based on both TCFD and Greenhouse Gas Protocol regimes, it stays focused on the SEC’s existing definition/interpretation of financial materiality and doesn’t attempt to wade into double or dynamic materiality of other ESG disclosure frameworks.
In terms of timing/phase-in, the proposal contemplates a phase-in period that would first require compliance from the largest filers in 2024 assuming the final rule is adopted and effective by December 2022.