Comment Letter
SEC Proposed Rule: The Enhancement and Standardization of Climate-Related Disclosures for Investors
Friday, June 17, 2022
The CAQ is pleased to share our thoughts and comments on the SEC’s proposed rule, The Enhancement and Standardization of Climate-Related Disclosures for Investors.
Public company auditors have long played a role in providing reliable information for decision-making for investors and other capital market stakeholders. Increasingly, that includes company-prepared climate and other ESG-related Information.
The CAQ is supportive of the SEC’s efforts to propose a rule that could provide both companies and investors clarity around ESG information that investors are increasingly asking for and that companies are already providing to some degree. In this comment letter, the CAQ:
- Supports the proposed rule requiring certain registrants to subject certain greenhouse gas emissions disclosures to assurance as this enhances the reliability of that information. There is an opportunity for the SEC to promote consistent, comparable, high-quality attestation over GHG emissions by further enhancing some of the attestation requirements in the proposed rule.
- Continues to support a globally accepted ESG reporting system developed from existing standards and frameworks, and that can be built upon to meet the needs of investors in different jurisdictions.
- Supports a phased-in approach to the proposed rule’s requirements. However, we recommend an alternative phased-in approach by both disclosure area and registrant type that would provide registrants with more time to prepare for those disclosure areas we think will take more time to adequately prepare for.
- Identifies challenges and recommendations around the organizational boundaries for GHG emissions disclosures, the lack of a specified framework for the GHG emissions methodology, and regulation S-X proposed amendments
Read the full comment letter here.
Roundtable Summary
In addition to the comment letter response, Ceres and the CAQ convened a virtual roundtable to discuss possible alternatives to the proposed Regulation S-X provisions in the proposed rule. The virtual roundtable brought together 18 participants representing public company auditors, institutional investors, and public company management. A summary of the discussion was submitted to the SEC. Download the summary of the roundtable discussion to understand stakeholder views on possible alternatives to the proposed Regulation S-X provisions.
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