Climate Change Disclosures in Annual SEC Filings

Considering SEC requirements, key issues and voluntary disclosure

By Ame Wellman Lewis and Laura A. Baumann

As annual reporting season approaches, public companies may want to consider climate change issues when determining material information to be disclosed under SEC Regulation S-K. Increases in climate change regulation, certain environmental issues affecting the registrant's industry or assets, and the adoption of corporate “green” initiatives to address climate change may impact the registrant's financial condition or competitive position.

As more investors become interested in companies' environmental, social and corporate governance practices, public companies may voluntarily elect to include information related to climate change in their SEC filings. Companies should consider disclosing the physical, regulatory and financial consequences that climate change may have on their business.

Disclosure of climate change issues will be most arduous for companies with significant greenhouse gas emissions, such as airlines; trucking or other companies with fleets of vehicles; manufacturing companies; oil and gas companies and other businesses that rely on coal or oil as their primary fuel sources; and those directly tied to the weather, such as ski resorts, and agricultural, timber and insurance companies. Continue reading...

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