Regulatory Filing

Comments on the SEC’s Proposed Climate Disclosure Rule

June 17, 2022

ACEEE filed comments in response to the Securities and Exchange Commission's (SEC’s) proposed rule on "The Enhancement and Standardization of Climate-Related Disclosures for Investors.” The pending proposal would, for the first time, require companies to disclose the increasing risks they face because of climate change and their efforts to mitigate the risks. The comments commend SEC’s plan to require disclosures of companies’ direct and indirect emissions, especially its proposed requirement of disclosure of scope 3 emissions data. However, ACEEE also highlights missed opportunities for consistent reporting of energy efficiency actions and achievements as well as guidance on how companies can report the indirect emissions effects from their products and services, or emissions “handprint;” and makes recommendations for how SEC could require reporting of these activities in a final rule.

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Energy Efficiency and Climate Change
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