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SEC climate disclosure proposal: Implementation considerations


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On March 21, the SEC published a widely anticipated proposal to enhance companies' climate-related disclosures. In addition to details regarding how management identifies, assesses, and manages climate-related risks and the related impact on financial metrics, the proposal calls for companies to provide information about how their boards provide oversight of climate-related matters.

In this episode, Heather Horn was joined by Brigham McNaughton, a managing director in PwC’s ESG practice, to discuss the challenges and opportunities companies face as they consider how to implement the SEC's climate disclosure proposal.

In this episode, you will hear:

  • 1:13 - An overview of the implementation questions companies are asking
  • 4:53 - Physical and transition risk disclosure requirements of the proposal, and how those terms are defined
  • 17:08 - Navigating the 1% rule for the financial statement disclosures
  • 21:14 - How companies can ensure their processes, controls and data are sufficient to meet the proposal requirements
  • 28:04 - Emissions disclosures and using carbon offsets, and the related attest considerations
  • 35:45 - What to focus on when developing new climate goals and targets
  • 43:28 - Global outlook - the CSRD and ISSB proposals
  • 48:53 - Final advice on the future of ESG reporting

Want to learn more about the SEC’s proposal? Listen to our previous podcasts that provide a closer look at governance, related investor perspectives, and legal and regulatory perspectives. Also refer to the text or audio version of our In the loop, The SEC wants me to disclose what?

Brigham McNaughton is a managing director in PwC’s ESG practice. He has served global clients in a range of industries including utilities, automotive, and financial services, advising on core ESG strategy development and stakeholder engagement. Brigham has worked closely with the Sustainability Accounting Standards Board on a variety of reporting initiatives.

Heather Horn is PwC’s National Office thought leader, responsible for developing our communications strategy and conveying firm positions on accounting and financial reporting matters. She is the engaging host of PwC’s accounting and reporting weekly podcast and quarterly webcast series. With over 30 years of experience, Heather’s accounting and auditing expertise includes financial instruments and rate-regulated accounting.

Transcripts available upon request for individuals who may need a disability-related accommodation. Please send requests to [email protected].

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