Retailers Detail Concerns on SEC Climate Disclosure Rules

Retailers Detail Concerns on SEC Climate Disclosure Rules

Retailers Detail Constructive Concerns on SEC Climate Disclosure Draft Rules

Washington, DC –The Retail Industry Leaders Association (RILA) filed comments with the Securities and Exchange Commission (SEC) Friday outlining how to address significant retail concerns with the agency’s proposed climate disclosure rules. 

“RILA and its members fully support the SEC’s goal of providing investors with accurate material climate risk-related information but have serious concerns about the prescriptive approach taken by the SEC in the proposed rules,” said Kathleen McGuigan, RILA executive vice president and deputy general counsel. 

RILA’s comments outline five major areas of concern regarding the proposed rules and identifies other areas where clarification, modification or deletion may be appropriate.

“The one-size fits all SEC approach in the draft rules will undoubtedly lead to disclosure overload resulting in unhelpful disclosures that are inconsistent, incomparable, and unreliable for investors. The significant compliance costs and burdens will have the unintended consequence of undermining companies’ ongoing proactive ESG efforts, beyond just emissions reduction,” said McGuigan. “RILA’s comments seek to provide the SEC with constructive recommendations to make the final regulations more practical and ultimately more useful to investors to evaluate companies’ climate risks as part of their investment and voting decisions and identify ways the SEC can minimize the rules’ unintended adverse consequences.”

As the SEC moves forward with this rulemaking, the retail industry continues to work diligently to address and reduce the retail industry’s climate change impact.[1] Among the efforts outlined in RILA’s Retail Climate Priorities and Retail Climate Action Blueprint, RILA members are building and retrofitting facilities and stores to increase energy efficiency and use of renewable energy, transitioning to new refrigerants with less global warming impact, increasing product efficiency, and streamlining and improving supply chain, transportation, and distribution systems to decrease GHG emissions and improve climate resilience. 

“Climate change is a bigger threat than any one individual, company, industry, or government can address on its own and can only be abated through the collective efforts of all parties. Retailers are a valued partner in the fight on climate change. RILA has appreciated the SEC’s willingness to meet with retail leaders over the past several months and welcomes the opportunity to continue discussions on how to solve for key proposed rule concerns and overcome implementation issues, leveraging retailers’ practical experience with ESG reporting,” said Erin Hiatt, RILA vice president, corporate, social responsibility (CSR). “We urge the SEC to continue to engage impacted stakeholders and act thoughtfully as they work to finalize the mandatory climate disclosure rules.”  

[1] For additional information regarding the efforts of RILA and its members to lower GHG emissions in retail operations, see RILA Sustainability Committee,; Retail Sustainability Model,; Energy Network,; Retail Energy Model,; DOE cooperative agreement project,; Zero Waste Network,; Environmental Compliance Network,; and Retail Compliance Center,


RILA is the US trade association for leading retailers. We convene decision-makers, advocate for the industry, and promote operational excellence and innovation. Our aim is to elevate a dynamic industry by transforming the environment in which retailers operate.

RILA members include more than 200 retailers, product manufacturers, and service suppliers, which together account for more than $1.5 trillion in annual sales, millions of American jobs, and more than 100,000 stores, manufacturing facilities, and distribution centers domestically and abroad.

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