Alert
Alert
04.01.25
On March 6, 2024, the Securities and Exchange Commission (SEC) adopted final rules imposing new climate-related disclosure requirements on domestic and foreign registrants with respect to their annual reports and registration statements (Rules). Compliance was set to begin as early as the annual reports for December 31, 2025, for calendar-year-end issuers classified as large-accelerated filers.
Despite the Rules having scaled back many of the proposals from 2022, they have been the subject of a number of legal challenges, culminating in a consolidated action before the U.S. Court of Appeals for the Eighth Circuit (Iowa v. SEC, No. 24-1522 (8th Cir.)). Pending the outcome of such action, the SEC had stayed effectiveness of the Rules.
On March 27, 2025, the SEC voted to end its defense of the Rules and sent a letter to the court withdrawing its defense of the Rules and confirming that “Commission counsel are no longer authorized to advance the arguments in the brief the Commission had filed.”
For additional background, see our client alert issued on March 27, 2024.