A PDF version of this publication is attached here: Today's SEC climate disclosures - how do you measure up? (PDF 887kb)

The SEC’s sweeping climate-related disclosure proposal released in March 2022 continues to be a focal point for companies and investors as stakeholders anticipate what may be included in the final release, and perhaps even more importantly, when the new rules will go into effect. The forward looking focus is perhaps understandable given the extent of the SEC’s anticipated disclosures coupled with the looming global ESG disclosure requirements that are expected to impact many US companies. Notwithstanding this ongoing activity, registrants need to ensure that the SEC’s existing long-standing climate-related disclosure requirements are fully embraced in the upcoming reporting cycle.

In September 2021, the Division of Corporation Finance released a “Dear Issuer” letter highlighting areas of potential comment related to climate disclosures. And, through November 30, 2022, climate disclosure is one of the top areas of SEC comment in their review of filings. Echoing this demonstrated interest from the SEC staff, PwC’s 2022 Global Investor Survey highlighted investors’ requests for additional sustainability information. ¹ Further, per 1 the survey, 60% of investors want companies to report the impact they have on the environment or society now and in the future.

This publication provides observations from our analysis of disclosures in the most recent annual SEC filings from the S&P 100, and is intended to assist companies in meeting regulator and investor disclosure expectations. While every company will differ, a greater understanding of how others are addressing the current requirements may be helpful in preparing year end disclosures. Although the themes observed in our analysis generally transcend industries, we have also included further detail by industry in the appendix.