Milbank LLP Environmental Law partner Matthew Ahrens and associate Allison Sloto have authored “SEC Increasingly Scrutinizing Companies’ Voluntary Climate Change Disclosures,” an article published on The Milbank General Counsel Blog.
The SEC has been increasingly scrutinizing companies’ voluntary climate change disclosures as it moves closer to mandating reporting on greenhouse gas emissions and climate risks. Mandatory reporting of these risks is widely expected to be a component of the SEC’s anticipated Environmental, Social and Governance (ESG) disclosure rules, but the SEC has also taken the position that climate change risks already fall within the realm of a number of its disclosure rules.