SEC climate rescission comment deadline keeps US disclosure strategy in flux

The SEC’s proposed rescission of its climate-related disclosure rules was published in the Federal Register on June 3, with comments due August 3. The proposal would rescind amendments under the Securities Act and Exchange Act that require registrants to provide certain climate-related information in registration statements and annual reports. Public-company counsel still need to manage climate disclosure as a live governance problem. Even if the SEC rule falls away, existing materiality-based disclosure, state climate laws, non-US rules and voluntary reporting commitments continue to create legal risk.