SEC Officially Pulls Back Climate Disclosure Reporting Rule

On May 29, the SEC proposed to rescind its climate disclosure rule—which had been pending implementation—citing legal authority concerns, implementation complexity, and an emphasis on a materiality-focused disclosure framework for public companies. 

For RILA members, these concerns are consistent with our advocacy throughout this rulemaking. Publicly traded companies will avoid prescriptive, one size fits all climate reporting and will be able to focus disclosures on climate related information that is already material under existing SEC requirements. 

This approach aligns with RILA’s historical advocacy regarding SEC climate disclosure.

RILA Position: Materiality-Based Disclosure, Practical Implementation

RILA has long supported a disclosure framework that delivers useful, relevant information to investors and stakeholders while avoiding overly prescriptive, costly mandates disconnected from retailers’ operations and data access. In prior comments, RILA emphasized that climate disclosures should focus on material risks and impacts within a company’s control, be operationally feasible, and avoid requirements—such as Scope 3 mandates—that introduce significant complexity and legal exposure without clear investor benefit.

The SEC’s proposed rescission aligns with—and in several respects exceeds—this position by removing the broader mandatory framework and reaffirming a materiality-focused standard. Even so, RILA members must continue to comply with applicable climate reporting laws, including California’s statutes (which are partially stayed), and the EU’s Corporate Sustainability Reporting Directive. Retailers should also continue to assess what voluntary climate reporting is appropriate for the needs of their non-regulatory stakeholders.

Rescinding the rule provides needed clarity to retailers about their financial reporting burdens, allowing for flexibility and business judgment appropriate to each business’ opportunities, challenges, stakeholders, geographic locations and markets. This means retail teams can spend less time on extensive reporting and more time on the efficiency and emissions reduction efforts that provide their businesses with cost certainty, resiliency, and risk mitigation. 

Conclusion

RILA members are encouraged to share questions or feedback with RILA to inform potential ongoing advocacy and implementation support.