The SEC’s climate disclosure rule is not in force. The Commission proposed rescinding it in full on May 29, 2026, and no company is currently required to comply with any part of it. No compliance deadline is active. The original phased timeline still appears in the rule text adopted in March 2024, but it has been frozen since April 2024, first by a voluntary stay and then by the SEC’s decision to stop defending the rule in court.
How the Rule Reached This Point
The SEC adopted the final climate disclosure rules on March 6, 2024, under then-Chair Gary Gensler. Challengers filed petitions for review within days, and the Judicial Panel on Multidistrict Litigation consolidated them in the U.S. Court of Appeals for the Eighth Circuit on March 21, 2024. On April 4, 2024, the SEC voluntarily stayed the rule pending the outcome of that litigation.1Securities and Exchange Commission. Order Issuing Stay
The stay left the rule on the books but suspended every deadline. After the change in administration, Acting Chairman Mark Uyeda called the rule “deeply flawed” on February 11, 2025, and directed staff to ask the Eighth Circuit to hold off on oral argument.2Securities and Exchange Commission. Acting Chairman Statement on Climate-Related Disclosure Rules On March 27, 2025, the Commission voted to stop defending the rule.3Securities and Exchange Commission. SEC Proposes Rescission of Climate-Related Disclosure Rules
The Eighth Circuit held the consolidated petitions in abeyance on September 12, 2025, telling the SEC to either reconsider the rules through notice-and-comment rulemaking or return to defend them. The SEC chose the first path. On May 29, 2026, Chairman Paul Atkins proposed rescinding the climate disclosure rules in their entirety, saying that “SEC disclosure obligations should comply with the Commission’s statutory authority, be guided by materiality as the North Star, avoid the practical effect of dictating corporate behavior, and be imposed only when the expected benefits justify the likely costs and burdens.” A 60-day public comment period follows publication in the Federal Register.3Securities and Exchange Commission. SEC Proposes Rescission of Climate-Related Disclosure Rules
The rescission is not yet final. A Commission that voted to propose full elimination, however, is not likely to reverse itself after the comment window closes. The court, for its part, is waiting on the agency rather than the other way around.
The legal backdrop also matters. In June 2024, the Supreme Court’s decision in Loper Bright Enterprises v. Raimondo overturned Chevron deference. Courts must now exercise independent judgment about whether an agency acted within its statutory authority, rather than deferring to reasonable agency interpretations. Any future attempt to revive climate-specific SEC disclosure requirements would face a harder legal path than the 2024 rule did.
What Public Companies Have to Do Right Now
Nothing under this rule. The stay took effect in April 2024 and remains in place. No filer, of any size, is required to prepare climate risk narratives, board oversight descriptions, greenhouse gas emissions figures, attestation reports, or financial statement notes on severe weather costs under the SEC climate rule. There is no deadline to track, no phase-in that has started, and no penalty for the absence of these disclosures in current filings.
General materiality obligations under existing securities law have not changed. If climate change poses a genuine threat to a company’s operations or financial condition, the longstanding materiality standard already requires disclosure of that risk. The climate rule would have standardized the format and content of that disclosure; its absence does not eliminate the underlying duty to disclose material risks.
What the Rule Would Have Required
The dates and thresholds below come from the final rule text as adopted in March 2024. All of them are frozen, and the SEC has proposed eliminating them. Companies that built internal planning around these milestones can set that planning aside unless and until the rescission is withdrawn.
The rule used a tiered compliance schedule based on filer category. Large accelerated filers, meaning issuers with a public float of $700 million or more, would have begun climate risk disclosures, board oversight descriptions, and qualitative assessments with fiscal years beginning in 2025. Accelerated filers, with public floats between $75 million and $700 million, would have picked up the same qualitative disclosures for fiscal years beginning in 2026. Non-accelerated filers, smaller reporting companies, and emerging growth companies were also targeted for fiscal years beginning in 2026, with some size-based accommodations. The disclosures would have been folded into existing Regulation S-K and Regulation S-X filings.4Securities and Exchange Commission. The Enhancement and Standardization of Climate-Related Disclosures for Investors
Greenhouse gas reporting was staggered separately. Large accelerated filers would have reported Scope 1 (direct emissions from sources the company owns or controls) and Scope 2 (indirect emissions from purchased electricity or heating) for fiscal years beginning in 2026. Accelerated filers would have started Scope 1 and Scope 2 reporting for fiscal years beginning in 2028. Smaller reporting companies and emerging growth companies were permanently exempt from greenhouse gas reporting.5Securities and Exchange Commission. The Enhancement and Standardization of Climate-Related Disclosures for Investors
The final rule did not require Scope 3 emissions reporting. The 2022 proposal had included Scope 3 (value-chain emissions from suppliers and customers), but the Commission dropped that requirement in response to opposition, making Scope 3 disclosure voluntary.4Securities and Exchange Commission. The Enhancement and Standardization of Climate-Related Disclosures for Investors
Third-party attestation of greenhouse gas data was phased in over several years, moving from limited assurance (a moderate review checking for obvious problems) to reasonable assurance (closer to a financial statement audit) for large accelerated filers, with accelerated filers required to reach limited assurance only. Financial statement notes would have disclosed the costs of severe weather events, subject to a one-percent and de minimis threshold. Forward-looking climate disclosures on transition plans, scenario analysis, internal carbon pricing, and targets received Private Securities Litigation Reform Act safe harbor protection.4Securities and Exchange Commission. The Enhancement and Standardization of Climate-Related Disclosures for Investors
Climate Reporting Obligations That Still Apply
The SEC rule’s likely demise does not clear the field. Companies operating across jurisdictions face separate climate reporting frameworks that remain in force.
California enacted two laws in 2023 that apply to both public and private companies doing business in the state, regardless of where they are incorporated. One requires companies with more than $1 billion in annual revenue to report Scope 1, 2, and 3 greenhouse gas emissions annually. The other requires companies with more than $500 million in revenue to publish biennial climate-related financial risk reports. The California emissions scope is broader than what the SEC rule would have required, because it captures the Scope 3 value-chain emissions the SEC declined to include.
The European Union’s Corporate Sustainability Reporting Directive also reaches U.S.-based companies. Non-EU companies generating more than €150 million in annual EU revenue, with at least one EU subsidiary or branch meeting certain thresholds, must begin reporting for fiscal years starting on or after January 1, 2028. For large multinationals, EU climate reporting sits outside anything the SEC does or does not require.
A company that scoped its climate reporting program to the SEC rule should reassess against these external frameworks rather than shutting the program down. The SEC deadline is gone; the California and EU deadlines are not.