On March 6, 2024, the Securities and Exchange Commission (SEC) in a 3-to-2 vote adopted its landmark climate-related disclosure rules, which will significantly expand the climate-related information that U.S. public companies and foreign private issuers (other than Canadian issuers reporting on Form 40-F) will be required to disclose in their periodic reports and registration statements. This memorandum supplements our March 7, 2024 publication and provides additional analysis of the Final Rules and key implications for public companies, which include the relatively short initial compliance timeline, interpretive challenges, liability considerations and overlapping requirements in other jurisdictions. Parties have already begun to challenge these rules in court, which further amplifies uncertainty.
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