Reporting on Climate Risks

Rules proposed by the Securities and Exchange Commission (SEC) in March 2022 would require excessive reporting by registered companies to exactly quantify emissions and financial risks from climate change — through metrics that are unknown, unknowable, and premised on speculations and hypotheticals.

The SEC’s proposal would impose “one size fits all” requirements on companies to disclose in their 10-Ks climate-related risks and emissions, including Scope 3.


Real estate companies should not be under a mandate to report on GHG emissions from sources they do not own or control—such as from their tenants or product manufacturers.

Calculating GHG emissions is more art than science. When reporting, companies should be protected from liability if they estimate emissions using the latest, best available U.S. government data and tools.


The SEC has yet to issue any final climate risk reporting rule. When it does, it will likely be subject to litigation. The effective date of any ultimate rule is thus uncertain.

The Roundtable submitted comments to the SEC on its proposed climate risk reporting rule that addressed key principles such as:

  • Registered companies should not be required to report on emissions from sources they do not own or control.
  • The SEC should provide a “safe harbor” for emissions calculated with U.S. government data and tools.
  • There should be no Scope 3 reporting “mandate.”
  • The SEC should wait until a registrant has a full year of “actual” data before requiring emissions disclosures.
  • Financial risks from severe weather events should be subject to “principles-based” reporting—as opposed to one-size-fits-all “prescriptive” rules.