A PDF version of the full publication is attached here: Measuring year-over-year progress in SEC sustainability disclosures (PDF 952kb)
While we wait for the finalization of the SEC’s climate disclosure rules, the quality of climate-related disclosures under existing securities laws continues to be a focal point for the SEC staff. Looming global ESG disclosure requirements are also inspiring a renewed corporate focus on disclosures of climate and other environmental risks amid ongoing investor demand for increased transparency to inform decision making.
Since its September 2021 issuance of a “Dear Issuer” letter highlighting climate disclosure considerations, the sufficiency of climate-related disclosures in annual filings has been one of the top areas of SEC comment. Based on publicly released data as of June 2023, 17 of the S&P 100 companies have received climate-related comments since the 2021 guidance was issued. Echoing this demonstrated interest from the SEC staff, PwC’s 2022 US Investor Survey highlighted investors’ requests for additional sustainability information, finding that 55% of US investors want companies to report the impact they have on the environment or society now and in the future.
Given the continued interest from investors and the SEC staff, we wanted to see whether and how climate-related disclosures in annual reports are evolving. We updated and expanded our December 2022 analysis of climate-related disclosures among the S&P 100 to compare the results from our prior analysis of 2021 10-Ks to the disclosures contained in the S&P 100’s 2022 10-Ks.
As companies look ahead to their next SEC filings, this publication provides insights into trends in disclosures so companies can assess how they measure up against other large companies and industry peers. Such a comparison can assist companies in meeting regulator and investor disclosure expectations. While every company differs, a greater understanding of how others are addressing the current requirements may be helpful in preparing disclosures.
While many of the themes in our analysis transcend industries, we have included further detail by industry in the appendix.
To read the full In the loop publication, download our PDF: Measuring year-over-year progress in SEC sustainability disclosures
2 2021 10-Ks refers to 10-Ks filed between June 1, 2021 and May 31, 2022. We have adjusted certain 2021 information from how it was presented in our December 2022 report to reflect a comparable year-over-year analysis.
3 2022 10-Ks refers to 10-Ks filed between June 1, 2022 and May 31, 2023.
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