On March 6, 2024, the SEC adopted final rules (Final Rules) requiring extensive climate-related disclosures in companies’ annual reports and registration statements. The new rules are set forth in Release No. 33-11275. The climate disclosure rules were proposed in March 2022 and drew considerable attention, with the SEC receiving approximately 24,000 comment letters from a variety of stakeholders (including Fenwick). Many of the comment letters from reporting companies and their advisors expressed concern around the extremely detailed, prescriptive and burdensome nature of certain provisions in the proposed rules.
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