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SEC’s Final Climate-Related Disclosure Rules

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March 28, 2024 • 2-minute read

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After much anticipation, on March 6, 2024, the Securities and Exchange Commission (“SEC” or the “Commission”) released its Final Rule—The Enhancement and Standardization of Climate-Related Disclosures for Investors—mandating climate-related disclosures by public companies. The Final Rule comes almost two years after the SEC first released its proposed rule and follows the submission of over 24,000 comment letters on many of the proposed rule’s requirements. Significantly, the Final Rule diverges in many key respects from the proposed rule—changes which our White Paper will further explore and that are depicted in the table set forth under Annex B to the White Paper—but that has not stopped the legal challenges from flooding in.

At the time of publication, nine petitions for review have already been filed in the Second, Fifth, Sixth, Eighth, Eleventh, and D.C. Circuits. On March 21, 2024, the Judicial Panel on Multidistrict Litigation randomly selected the U.S. Court of Appeals for the Eighth Circuit (the “Eighth Circuit”) as the venue in which the consolidated appeals will be litigated. The next day, the United States Court of Appeals for the Fifth Circuit (the “Fifth Circuit”) transferred the cases that had been filed in that Court to the Eighth Circuit and also lifted the temporary administrative stay that it issued against the Final Rule on March 15, 2024. Several of the challengers to the Final Rule have since asked the Eighth Circuit to issue a new stay; as of the time of publication, the Eighth Circuit had not yet ruled on those requests. While it is difficult to predict how the litigation will unfold in the coming weeks and months, our White Paper aims to provide an in-depth overview of the content of the Final Rule, how it may impact registrants, and how registrants should consider these developments in light of other regulatory and stakeholder pressures.

This information is provided by Vinson & Elkins LLP for educational and informational purposes only and is not intended, nor should it be construed, as legal advice.

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