Following the recent ruling by a Dutch court that Shell should reduce its carbon emissions and the climate votes at recent listed company AGMs around the world, all businesses with a significant carbon footprint – regardless of which sector or jurisdiction they operate in – should engage urgently on their climate strategy and targets. 

In this note we highlight key points for businesses to consider for their climate strategy and targets.

The SEC Proposal is based in part on the recommendations (the “TCFD Recommendations”) of the Task Force on Climate-related Disclosures (the “TCFD”). The TCFD Recommendations have gained widespread acceptance as a global standard for climate-related disclosures and, as a result, a number of jurisdictions (including Canada, Hong Kong, Japan, New Zealand, Singapore and Switzerland) have either mandated TCFD-aligned reporting in domestic regulation, or are in the process of doing so. 

The U.S. Securities and Exchange Commission has released its climate disclosure proposal, a potentially major expansion of the U.S. public company reporting regime that would require climate-related disclosures in registration statements and annual reports and associated financial statements. As proposed, the requirements would apply to U.S. domestic and foreign private issuer registrants and would require accelerated and large accelerated filers to obtain an independent attestation report covering, at a minimum, Scope 1 and 2 greenhouse gas (“GHG”) emissions disclosure. 
 

Focussing mainly on developments in the EU and the UK, and measured against other key global and regional programmes and initiatives, our panel of experts will guide you through these developments and their associated milestones, and offer practical guidance on how they impact your institutions.

On June 17, 2022, the SEC's comment period for its March 2022 climate disclosure proposal closed. This article outlines a number of significant comments that were submitted in the last week of the comment period from Linklaters, Blackrock, SIFMA, members of Congress and The Working Group on Securities Disclosure Authority.