SEC Formally Proposes Climate Disclosure Rescission — State Rules Fill the Vacuum

The SEC voted on May 29, 2026 to propose full rescission of its March 2024 Climate-Related Disclosure Rules, published in the Federal Register on June 3 with a public comment period that closed August 3. The proposal would eliminate all mandatory climate risk, GHG emissions, and financial statement climate metrics requirements for public companies — reverting issuers to existing, principles-based obligations under Regulation S-K and S-X, where material climate risks still must be disclosed. Importantly, Debevoise flagged that anti-fraud provisions continue to apply to any voluntary sustainability claim in SEC filings or sustainability reports, so the rescission does not remove legal risk for companies making affirmative climate statements. The practical compliance consequence is now state-level: California's SB 253 Scope 1 and 2 emissions reporting deadline has been shifted by CARB from August 10 to November 10, 2026, following withdrawal of the current rulemaking text — but the underlying law and obligation remain active, and multi-jurisdictional coordination is now the primary compliance challenge for US-listed companies operating across multiple state frameworks.