The U.S. Securities and Exchange Commission's Division of Corporation Finance is enforcing the 2010 Climate Change Guidance. Leading law firms have recently advised their clients of this, see these alerts below. And, the SEC is expected to release a proposed rule on mandatory climate disclosure in early 2022, following their request for public comment in March 2021. In response to that RFI, 70% of investors call for rules that align with the Task Force on Climate-related Financial Disclosures recommendations, and 65% call for disclosure of greenhouse gas emissions, scopes 1, 2 & 3, with a range of proposed accommodations for scope 3, including safe harbors for liability and phase-in periods.  
Investors want companies to disclose greenhouse gas emissions and assumptions underlying climate commitments, targets, and strategy, including scenario analyses. The position companies take on this mandatory climate disclosure rule will be under intense scrutiny - by investors, the general public, host communities where you operate, and other stakeholders. We encourage companies to welcome this proposed rule, submit a supportive public comment, and take a leadership position on climate disclosure in your industry.

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