TO COMPLY WITH THE SEC'S NEW RULES, ELIGIBLE ORGANIZATIONS AND ISSUERS
WILL NEED TO TAKE THE FOLLOWING ANNUAL COMPLIANCE STEPS, STARTING IN
2023 (AS THE TIMELINE CURRENTLY PROPOSED STANDS):
Integrate climate risk and carbon accounting into your
regular financial accounting and regulatory reporting
cycles.
Track and disclose the required information - SEC reports
will likely require management commentary and data on
a company's:
1
Materiality outlook to select material ESG themes, topics, risks, and
focus areas
2
Details on how the board and management exercise their oversight
and set climate-related targets and goals, as well as disclosure
regarding climate-related expertise
3
Sustainability and ESG performance targets, goals, and progress
4
Sustainability and environmental risks (including climate change)
affecting the company
5
How sustainability and ESG risks could or are impacting operating
results, financial performance, and shareholder value
6
Scope 1-2-3 GHG disclosure
7
Any ESG or climate analytics tools, such as scenario analysis, the
registrant uses to assess the impact of climate-related risks on its
business and consolidated financial statements, or that support
business model resilience in light of foreseeable climate-related
risks
8
Relevant information on an organization's use of carbon offsets,
credits, and/or renewable energy credits or certificates (RECs) as
part of the company's overall net emissions reduction strategy
Third party attestation
The proposed rules require accelerated filers and large accelerated filers
reporting climate-related disclosures to the SEC to include an
attestation report from a neutral, trusted, and experienced third party
covering, at a minimum, the disclosure of the company's Scope 1 and
Scope 2 emissions. This report should also include certain related
disclosures about the attestation service provider. This is "limited"
assurance of the ESG information being disclosed, which is less strict
than a financial audit, but still requires working with a sustainability
reporting partner organization.
What
to
do
to
get
SEC-ready: