Climate Disclosures - A Deep Dive Into the SEC’s Proposed New Greenhouse Gas Disclosures and Attestation Requirements

In a highly anticipated meeting, on March 21, 2022, the U.S. Securities and Exchange Commission (“SEC”) proposed sweeping new climate change disclosure requirements.  This Briefing focuses on proposed new disclosures about Greenhouse Gas Protocol Scope 1, 2 and 3 emissions and the related attestation requirements for accelerated and large accelerated filers.  Discussion will include the process of measuring greenhouse gas emissions, the complexities in measuring Scope 3 emissions, greenhouse gas intensity disclosures, and the levels of attestation as the disclosure phases-in.  Companies should begin planning now for more extensive and complex disclosure requirements likely to be enacted from this proposal.  Please join SEC Institute Directors Bob J. Laux and George M. Wilson as they discuss the proposed disclosure requirements and what to do now to plan for the new disclosures.

In this Briefing faculty will:

• Discuss the rationale for the changes presented in the SEC’s proposed rule – 3 minutes
• Explain the foundations for the proposed rules in the Greenhouse Gas Protocol of 2001– 5 minutes
• Define Scope 1, 2 and 3 emissions – 5 minutes
• Scope 1 – Direct GHG emissions
• Scope 2 – Indirect emissions from purchased energy
• Scope 3 – Indirect emissions not included in Scope 2
• Upstream
• Downstream
• Review Scope 1 and 2 disclosure requirements– 10 minutes
• Separate disclosure of Scope 1 and Scope 2 emissions
• Sources included in organizational and operational boundaries
• Disaggregated by greenhouse gas
• Considerations for investments not consolidated
• Exclusion of purchased or generated offsets
• Related intensity disclosures
• Review Scope 3 disclosure requirements– 15 minutes
• Scope 3 if material or if target set by company
• Exclusions for smaller reporting companies from Scope 3 disclosures
• Description of sources of data
• Upstream consideration
• Downstream considerations
• Description of data and information about parties in company’s value chain
• Safe harbor provisions
• Related intensity disclosures
• Explain the proposed attestation requirements for large accelerated filers and accelerated filers for Scope 1 and 2 disclosures– 10 minutes
• Who will perform the attestation examination?
• Use of “publicly available standards”
• Levels of assurance during the phase-in period
• Required disclosures
• Discuss phase-in requirements – 2 minutes
• Enumerate action steps for companies to consider – 10 minutes

You may also be interested in PLI’s two related One-Hour Briefings focused on the non-financial statement and financial statement disclosure requirements in the SEC’s Proposed Rule for climate-related disclosures.

If you would like an overview of the proposed rule, PLI’s One-Hour Briefing “Climate Change – The SEC’s Proposed New Disclosures” is available on-demand.