The U.S. Securities and Exchange Commission&#39;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 &amp; 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. 

We have reviewed your filing and have the following comments regarding compliance with the topics addressed in the Commission’s 2010 Guidance Regarding Disclosure Related to Climate Change, Release No. 33-9106 (Feb. 2, 2010).

SEC  Sample Letter to Companies Regarding Climate Change Disclosures

[...] the [SEC comment letters on climate] serve as a useful reminder that, as part of a company's disclosure controls and procedures, climate-related information should be carefully considered for possible inclusion in a company's periodic reports.

SEC Staff Scrutiny of Climate Change Disclosures Has Arrived: What to Expect And How to Respond

If you’ve been fence sitting, you can no longer afford to wait and see. [...] ​​Detailed climate change disclosure is no longer a recommended best practice. It’s a requirement—or it will be very soon. And, no doubt, the rules will continue to evolve and become increasingly stringent over time.

It’s Official: New Climate Risk Disclosure Rules Are Coming Soon from the SEC - Clermont Partners

[...] SEC registrants are advised to review their current climate-related disclosure and begin to evaluate whether the existing disclosure would satisfy the considerations put forth by Chair Gensler.

SEC enforcing 2010 guidance on climate change disclosure and releasing a proposed rule for mandatory disclosure in early 2022

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