The SEC’s Revolutionary New Climate Disclosures – New Greenhouse Gas Disclosure, Attestation, and Financial Statement Disclosure Requirements

In a highly anticipated meeting, on March 6, 2024, the U.S. Securities and Exchange Commission (“SEC”) proposed sweeping new climate-related disclosure requirements. This Briefing focuses on new regulations requiring public disclosures about greenhouse gas (GHG) emissions and the related attestation requirements. It also reviews the new financial statement disclosure requirements. Discussion will include the process of measuring greenhouse gas emissions, greenhouse gas disclosure considerations, and the levels of attestation as the disclosures phase in. The accounting-related discussion will include disaggregated disclosure requirements, materiality considerations, and severe weather event disclosures. Please join expert faculty as they discuss the new GHG and financial statement disclosure requirements and what to do now to begin implementing the new requirements. 

In this Briefing faculty will:

• Explain the foundations for the rules in the Greenhouse Gas Protocol, Corporate Accounting and Reporting Standard (2004) and other standards– 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– 15 minutes
  • Required for large accelerated and accelerated filers only
  • Separate disclosure of Scope 1 and Scope 2 emissions, if material
  • Disaggregated by greenhouse gas, if material
  • The Final Rule’s lack of disclosure requirements for Scope 3 emissions
  • Exclusion of purchased or generated offsets
  • Option to disclose in Form 10-K or second fiscal-quarter Form 10-Q (or, in case of FPIs, equivalently timed amendment to Form 20-F)
  • Sources included in organizational and operational boundaries
  • Methodology, significant inputs and significant assumptions (including boundary differences from entities and operations in consolidated financial statements)
• Explain the 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
• Explain disclosure requirements for financial reporting, including the impact of severe weather events and natural conditions – 5 minutes
• Outline financial reporting materiality considerations – 8 minutes
• Discuss phase-in requirements – 4 minutes
• Enumerate action steps for companies to consider – 8 minutes

You may also want to listen to our related One-Hour Briefing focused on the non-financial statement and greenhouse gas emissions disclosure requirements in the SEC’s Rule for climate-related disclosures. You can find the briefing here: The SEC’s Revolutionary New Climate Disclosure Requirements – A Deep Dive Into Governance, Strategy, and Risk Disclosures.

Who Should Attend: Accountants and attorneys who deal with SEC reporting and disclosure and related accounting issues, including CFOs, controllers and their staff, internal auditors, partners of public accounting firms and their staff, in-house counsel, and outside attorneys.

Program Level: Update

Prerequisites: None

Advanced Preparation: None

Faculty:

Victoria Evans

Anthesis Group Ltd.

Alexandra N. Farmer

Kirkland & Ellis LLP

Kevin Vaughn

PricewaterhouseCoopers LLP