ACCA welcomes the opportunity to provide comment on The United States Securities and Exchange Commission’s (SEC) proposed rescission of climate-related disclosure rules. We recognize the Commission’s responsibility to ensure that disclosure requirements are legally sound and reflect its own policy objectives. We also acknowledge discussions regarding materiality, agreeing that disclosure requirements should remain focused on information that is decision-useful to investors. The same applies to their proportionality and relevance to the circumstances of individual registrants. 

However, ACCA disagree that the 2024 rule regarding climate-related disclosures is inconsistent with a registrant-specific, materiality-based approach. Instead, we believe that a standardized, global framework still provides companies the opportunity to determine what is material, while also providing comparable, decision-useful information to investors. We believe that the SEC’s concerns do not support rescinding the climate-related disclosures in their entirety.

Global research by ACCA has extensively studied and reviewed the impact of climate-related disclosures. This includes their role in corporate decision-making and, similarly, the benefits of globally consistent reporting for investors and businesses. While acknowledging the factors identified by the SEC in support of its proposal, ACCA highlights three broader considerations that should inform the SEC’s thinking. Those considerations include the overarching business case, global comparability and consistency, alongside corporate governance.

To read ACCA’s complete comments, please download the document found on this page.