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v1.2Last reviewed August 2026
Authored by Jeremiah Say

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SEC Climate Disclosure Rule

SEC climate disclosure rule methodology — adopted but never in force. As adopted, Release 33-11275 on 6 March 2024 required large accelerated filers above 700 million dollars public float to disclose Scope 1 and 2, with limited assurance by fiscal 2028 and reasonable by 2032. Current standing: voluntarily stayed April 2024, rescission proposed 29 May 2026 under Release 33-11421. Reference methodology only; verify current standing before relying.
MB v2026.193 · updated 14 Sep 2026

The SEC’s climate disclosure rule was adopted in March 2024, stayed weeks later, and has never taken effect. On 29 May 2026 the Commission formally proposed to rescind it.

This is reference methodology for a rule that exists on paper but imposes no current obligation — read it to understand what it required and what now applies instead, not to file under it today.

Quick Answer

The SEC climate disclosure rule (Release 33-11275, adopted March 2024) was stayed in April 2024 and never took effect. The SEC proposed to rescind it on 29 May 2026 (Release 33-11421), comment period open. No SEC climate-disclosure filing obligation is currently in force.

US Disclosure · 15 min read

Reference methodology for the US SEC climate-related disclosure rule: the filer categories and phase-in as adopted, the materiality gate, the Scope 1 and Scope 2 emissions disclosure (Scope 3 was dropped from the final rule), the limited-to-reasonable assurance phase-in, and the separable financial-statement provisions — alongside an honest account of the rule’s current legal standing and what actually applies to issuers now. Rule text per SEC Release 33-11275 (as adopted); current status per SEC Release 33-11421 and the Eighth Circuit docket.

Status (June 2026): adopted, stayed, never effective — and now proposed for rescission

The SEC climate disclosure rule is not in force. It was adopted on 6 March 2024 (Release 33-11275), voluntarily stayed by the Commission on 4 April 2024 pending litigation, and never took effect. The SEC voted to end its defense of the rule on 27 March 2025; the Eighth Circuit subsequently held the consolidated petitions in abeyance pending the SEC’s reconsideration. On 29 May 2026 the SEC proposed to rescind the rule in its entirety (Release 33-11421), with a comment period open. This is a proposed rescission, not a completed one — but no SEC climate-disclosure filing obligation is currently in effect. Treat this page as reference, verify the live status on SEC.gov before any decision, and see what actually applies now for the regimes that are operative.

A methodology page is the execution layer — normally it tells you exactly how to calculate and file. Here, because the rule never took effect, it does two jobs: document precisely what the rule required as adopted (so the reference is complete and durable), and state where that leaves issuers today. Jump to the Scope 1 & 2 methodology as adopted, or skip to what applies now.

2024-03-06
Adopted, 3–2 voteRelease 33-11275 (companion 34-99678) — “The Enhancement and Standardization of Climate-Related Disclosures for Investors”.
2024-04-04
Voluntarily stayedThe SEC stayed its own rule pending the consolidated litigation in the US Court of Appeals for the Eighth Circuit. The rule never came into force.
2025-03-27
SEC ends its defenseThe Commission voted to stop defending the rule in the Eighth Circuit litigation.
Sept 2025
Eighth Circuit holds petitions in abeyanceThe court paused the case until the SEC either reconsiders the rule by notice-and-comment rulemaking or renews its defense.
2026-05-07
SEC letter to the courtThe SEC informed the Eighth Circuit it would reconsider the rule by notice-and-comment rulemaking and would not renew its defense.
2026-05-29
Rescission proposed (current status)Release 33-11421 proposes to rescind the rule in its entirety. Comment period open. This is a proposal — not a completed rescission — but the rule remains stayed and not in force throughout.

Pre-check — which filer category would the rule have applied to? (as adopted)

The rule scaled obligations by filer category, defined by public float. Emissions disclosure (Scope 1 and Scope 2) would have fallen only on the two largest tiers; smaller reporting companies and emerging growth companies were exempt from the GHG-emissions disclosure entirely. These categories describe the rule as adopted — none of it is currently in effect.

Large accelerated filer (LAF)
Fullest obligation. Public float ≥ $700M. Climate-risk narrative + financial-statement disclosures + Scope 1 & 2 emissions (on a materiality trigger) + assurance phasing to reasonable. reporting.sec.filer.large_accelerated.public_float_usd_m
Accelerated filer (AF)
Emissions in scope. Public float $75M–$700M. Same narrative + financial-statement items + Scope 1 & 2 (materiality-triggered), but assurance stays at limited permanently. reporting.sec.filer.accelerated.public_float_usd_m
Smaller reporting company (SRC)
Exempt from emissions. Float < $250M, or revenue < $100M with float < $700M. Narrative + financial-statement items would apply, but no Scope 1/2 disclosure. reporting.sec.filer.smaller_reporting_company.exempt_emissions
Emerging growth company (EGC)
Exempt from emissions. Revenue < $1.235B (and within the EGC time-limited window). No Scope 1/2 disclosure. reporting.sec.filer.emerging_growth_company.exempt_emissions
Foreign private issuer (FPI)
In scope by float tier. FPIs would have been covered on the same float-based scaling, reporting on the relevant annual-report form. Many also report under IFRS S2 or CSRD in their home jurisdiction.

Two readings of this rule — what it said vs where it stands

This page keeps the two strictly separate. The left column is the rule as the Commission adopted it in March 2024 — the methodology of record, useful for understanding US disclosure design and for scenario-planning. The right column is its legal reality in mid-2026. Do not read the left as a current obligation.

As adopted (Mar 2024)

A phased, materiality-gated disclosure regime

Climate-risk governance/strategy/risk narrative, financial-statement footnote disclosures, and — for large accelerated and accelerated filers — Scope 1 and Scope 2 emissions where material, with assurance phasing in from limited to (for LAFs) reasonable. Scope 3 was dropped from the final rule. This is what the methodology below documents.

Current standing (Jun 2026)

Stayed, never effective, rescission proposed

Stayed since April 2024; the SEC ended its defense in March 2025 and proposed full rescission on 29 May 2026. No filing obligation is in force. US issuers face climate disclosure obligations from other regimes — notably California SB-253/261 — and many report voluntarily under IFRS S2 or the GHG Protocol. See what applies now.

Status: Why This Methodology Is Reference, Not a Live Obligation

Every other disclosure methodology on this site describes a regime you must comply with. This one is different, and the difference matters more than any calculation detail: the rule was adopted but stayed before it ever applied, and the SEC has now proposed to undo it. Reading the methodology as a live obligation would be a factual error.

That said, the rule is worth documenting precisely. It remains the most detailed statement of how US federal climate disclosure was designed to work; its filer-tier logic and materiality gate continue to inform voluntary practice and shape comparison with the regimes that are live; and a proposed rescission is not a completed one. The methodology below is the rule as adopted — accurate as a reference, not as instructions for a current filing.

Two parts of the regime have different fates — and one was never stayed

The climate rule (Scope 1/2 emissions and the new climate-risk disclosures) is stayed and proposed for rescission. But Item 105 of Regulation S-K already required disclosure of material climate-related risk factors before this rule and was never part of the stay — material climate risk remains a live disclosure consideration under existing securities law. Separately, the financial-statement provisions (Subpart 1500 / Regulation S-X Article 14) are a distinct, GAAP-audited limb that could in principle survive even if the emissions disclosure is struck. Do not treat “the rule is stayed” as “climate is irrelevant to SEC filings.”

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When to Use This Methodology

✓ Use this methodology when
  • You need to understand what the SEC climate rule required, as adopted, for reference or training
  • You are scenario-planning for a possible future US federal disclosure regime and want the design baseline
  • You are comparing US disclosure design against California SB-253/261, IFRS S2, or CSRD
  • You are assessing whether the separable financial-statement provisions affect your filings
✗ Do not use this methodology when
  • You are looking for a current SEC climate filing obligation — there is none in force; do not file under this rule
  • You need your live US-relevant obligation — see what applies now (California, and voluntary frameworks)
  • You are quantifying a corporate inventory — use the GHG Protocol directly; this rule only ever set a disclosure wrapper around Scope 1/2, not a new accounting method
  • You need legal advice on filing exposure — consult securities counsel; this page is factual reference, not legal advice

Step 1 — Filer Categories & Phase-In (As Adopted)

The rule scaled both what you disclosed and when by filer category. The thresholds below are the rule as adopted; the phase-in dates are the rule’s original schedule and were stayed before any of them took effect.

Filer category Threshold (public float / revenue) Scope 1 & 2 emissions? Original (stayed) first disclosure FY
Large accelerated filer (LAF) Public float ≥ $700M Yes — if material FY2025 (filed 2026) Stayed
Accelerated filer (AF) Public float $75M – $700M Yes — if material FY2026 (filed 2027) Stayed
Smaller reporting company (SRC) Float < $250M, or rev < $100M with float < $700M Exempt Narrative items only (also stayed)
Emerging growth company (EGC) Revenue < $1.235B (time-limited window) Exempt Narrative items only (also stayed)

Filer thresholds: SEC climate disclosure rules (Release 33-11275, as adopted). Values reproduced from the rule as adopted — none currently in effect.

Smaller reporting companies and emerging growth companies were exempt from emissions disclosure

A frequent misreading of the rule is that all filers would have reported Scope 1 and Scope 2. They would not. Only large accelerated filers and accelerated filers fell within the GHG-emissions disclosure, and even then only where the emissions were material. SRCs and EGCs were exempt from the emissions disclosure entirely (they would still have faced the narrative climate-risk items). Any model that applied emissions disclosure across all filer tiers over-stated the rule’s reach.

Step 2 — What the Rule Required — The Materiality Gate

The rule had two limbs: narrative climate-risk disclosures in the body of the annual report, and quantitative disclosures in or about the audited financial statements. Both were gated by materiality, and the emissions limb was further narrowed to the two largest filer tiers.

Material climate-related risk? to business strategy, results, or condition
Narrative disclosure: governance, strategy, risk management, and any climate targets/transition plan. This narrative limb echoes the four TCFD pillars. reporting.sec.rule.item_105.material_climate_risk (Item 105 risk factors predate the rule and were not stayed).
LAF or AF, and emissions material? two largest filer tiers only
Disclose Scope 1 and Scope 2 emissions (gross, by constituent gas where applicable), with assurance phasing in. SRCs and EGCs exempt. Scope 3 was dropped from the final rule entirely. reporting.sec.rule.scope_3.dropped_from_final
Severe-weather / cost thresholds met? in the audited financial statements
Financial-statement disclosures under Subpart 1500 / Regulation S-X Article 14 — severe-weather effects and carbon-credit/REC costs above the thresholds. Capitalized-cost threshold 1.0%; expensed-cost threshold 0.01% of the relevant line item. reporting.sec.rule.financial_statement.severe_weather
The financial-statement limb is separable — and audited

The Subpart 1500 / Regulation S-X Article 14 provisions sit inside the audited financial statements, subject to GAAP and the financial-statement audit, with quantitative bright lines (1.0% of capitalized costs; 0.01% of expensed costs for severe-weather effects, plus carbon-offset and renewable-energy-certificate cost disclosure). This is a structurally distinct limb from the emissions disclosure. In a partial-outcome scenario it could in principle survive even if the Scope 1/2 emissions disclosure is rescinded or struck — which is exactly why the two limbs are documented separately here.

Step 3 — GHG Emissions: Scope 1 & 2 on a Materiality Trigger (As Adopted)

Where the emissions limb applied — LAFs and AFs, material emissions — the rule did not invent a new accounting method. It required disclosure of Scope 1 and Scope 2 calculated on GHG Protocol principles. The methodology is the standard inventory calculation; the rule added a disclosure wrapper, a materiality gate, and assurance.

Why Scope 3 was dropped from the final rule

The 2022 proposal included Scope 3 disclosure where material or where the issuer had a Scope 3 target. The final 2024 rule removed Scope 3 entirely — a significant narrowing in response to cost, reliability, and value-chain-data concerns raised in the comment process. As adopted, the rule reached only Scope 1 and Scope 2; Scope 3 was outside it. This is a notable contrast with California SB-253 and CSRD, both of which do reach Scope 3.

The materiality qualifier and the LAF/AF-only scope

Two narrowings stacked: the emissions disclosure applied only to LAFs and AFs (SRCs and EGCs exempt), and even for those filers only where the emissions were material. The rule did not impose unconditional, universal emissions disclosure — a distinction often lost in summaries that describe it as “the SEC requiring all public companies to report emissions”. Neither part was ever tested in practice, because the rule was stayed before the first reporting year.

The Scope 1/2 figures would have been genuine GHG Protocol scopes

Unlike a CBAM embedded-emissions figure or an EU ETS allowance, the emissions the SEC rule would have required are ordinary GHG Protocol Scope 1 and Scope 2 — the same tonnes a voluntary inventory already computes. The rule was a disclosure-and-assurance wrapper, not a new measurement basis. The outside_scopes tag carried on the SEC rows in the GreenCalculus data layer marks them as regulatory threshold/framework metadata (filer floats, phase-in years), not as emission factors — it does not mean the rule’s emissions sit outside the GHG Protocol scopes.

Step 4 — The Assurance Phase-In (Limited → Reasonable)

The rule phased in third-party assurance over the emissions disclosure, and this is where the two emissions-reporting tiers diverged most sharply — a detail most summaries miss. The dates below are the rule’s original schedule (all stayed before taking effect).

Worked examples — the assurance timelines (as adopted)

Two timelines on a single fictional issuer, MKT Corp, shown first as a large accelerated filer and then as an accelerated filer. The years are the rule’s original phase-in relative to the first emissions-disclosure year; none took effect. The key MB-backed point: reasonable assurance was LAF-only — accelerated filers never advance past limited assurance.

Example 1 Large accelerated filer — assurance escalates to reasonable S1 S2 Stayed
Filer profile (as adopted)
MKT Corp — public float ≥ $700M → Large accelerated filer
First Scope 1 & 2 disclosure: FY2025 (filed 2026)
Limited assurance phase-in: year 3  |  Reasonable assurance: year 7 reporting.sec: limited_phase_in_years = 3; reasonable_phase_in_years_laf = 7. As adopted; stayed before any year took effect.
Limited assurance
First disclosure FYFY2025
+ phase-in (yr 3)FY2028
Assurance levelLimited
FY2028
limited assurance begins
Reasonable assurance
First disclosure FYFY2025
+ phase-in (yr 7)FY2032
Assurance levelReasonable (LAF only)
FY2032
reasonable assurance — LAF only
LAF path: disclosure FY2025 → limited assurance FY2028 → reasonable assurance FY2032. Reasonable assurance is the highest level and applies only to large accelerated filers.
“Limited” assurance is a negative-form conclusion (nothing came to the practitioner’s attention); “reasonable” assurance is a positive opinion, the level applied to audited financial statements. The step from limited to reasonable is a material increase in audit rigour and cost — which is why only the largest filers faced it.
Example 2 Accelerated filer — assurance never advances past limited S1 S2 Stayed
Filer profile (as adopted)
MKT Corp — public float $75M–$700M → Accelerated filer
First Scope 1 & 2 disclosure: FY2026 (filed 2027)
Limited assurance phase-in: year 3  |  Reasonable assurance: never AFs phase in limited assurance only; the reasonable-assurance escalation is LAF-only by design.
Limited assurance
First disclosure FYFY2026
+ phase-in (yr 3)FY2029
Assurance levelLimited
FY2029
limited assurance begins
Reasonable assurance
Applies to AFs?No
Ceiling for AFsLimited (permanent)
Reasonable tierLAF only
Never
AFs stay at limited permanently
AF path: disclosure FY2026 → limited assurance FY2029 → stays at limited. The reasonable-assurance step (FY2032 for LAFs) has no AF equivalent — a deliberate cost concession to the smaller of the two emitting tiers.
This LAF/AF assurance split is one of the most frequently mis-stated features of the rule. Reasonable assurance was never going to apply to accelerated filers; only large accelerated filers faced the escalation to a positive audit opinion.

Step 5 — What Actually Applies Now Instead

With the SEC rule stayed and proposed for rescission, the live climate-disclosure obligations US-connected issuers actually face come from other regimes. This is the section to act on.

California SB-253 & SB-261

The most consequential live US obligation. SB-253 requires large companies doing business in California (revenue over $1B) to report Scope 1, 2, and 3; SB-261 (revenue over $500M) requires biennial climate-risk disclosure. These reach many of the same issuers the SEC rule would have, and they do include Scope 3.

IFRS S2 (voluntary or home-jurisdiction)

The ISSB’s IFRS S2 is the global baseline succeeding TCFD, mandatory in a growing list of jurisdictions and used voluntarily elsewhere. US issuers with international listings or investor demand increasingly report against it. See the IFRS S2 methodology.

CSRD ESRS E1 (EU nexus)

US groups with qualifying EU operations may fall under the EU’s CSRD ESRS E1, a double-materiality regime reaching the full value chain. See the CSRD ESRS E1 methodology.

UK obligations & voluntary inventory

US groups with UK entities may face UK TCFD-aligned disclosure or SECR. Independent of any mandate, a GHG Protocol inventory remains the foundation all of these draw on.

“No SEC rule” does not mean “no US climate disclosure obligation”

The most damaging error a US issuer can make right now is to treat the SEC rule’s stay as the end of climate disclosure exposure. California SB-253/261 is live and reaches Scope 3; CSRD can apply through EU operations; existing SEC materiality principles (Item 105) still require disclosure of material climate risk; and investor and lender demand for IFRS S2-aligned data continues regardless of mandate. Map your live obligations to the regimes above, not to this rule.

SEC Rule vs California SB-253/261 vs IFRS S2 vs CSRD

Regime Status (Jun 2026) Emissions scope Materiality / trigger
SEC climate rule Stayed / rescission proposed Scope 1 & 2 (LAF/AF only); no Scope 3 Financial materiality; emissions-tier-gated
California SB-253/261 Live SB-253: Scope 1, 2 & 3 (rev > $1B) Revenue thresholds; doing business in California
IFRS S2 Live (by jurisdiction) Scope 1, 2 & 3 Financial materiality (investor focus)
CSRD ESRS E1 Live (EU) Scope 1, 2 & 3 Double materiality (impact + financial)

The clean mental model: the SEC rule was the narrowest of the four — Scope 1 and 2 only, largest filers only, financial materiality only — and it is the one not in force. The live regimes (California, IFRS S2, CSRD) are broader, all reach Scope 3, and all rest on the same GHG Protocol measurement underneath. An issuer that built a GHG Protocol inventory for the SEC rule has not wasted the work — that inventory is exactly what the live regimes require.

What a Calculator Handles vs What You Decide

Because the rule never took effect, a “SEC calculator” is really a structuring aid for understanding the regime and stress-testing readiness. The judgements remain yours.

⚙ A calculator could handle
  • Filer-category determination from public float and revenue
  • Whether the emissions limb would apply (LAF/AF vs SRC/EGC)
  • The assurance timeline by tier (limited at year 3; reasonable at year 7, LAF only)
  • Scope 1 + 2 totals from a GHG Protocol inventory
  • Financial-statement threshold tests (1.0% capitalized / 0.01% expensed)
  • Mapping the same inventory onto the live regimes (California, IFRS S2, CSRD)
✎ You must decide
  • Live obligation: which regimes actually bind you now (not this rule)?
  • Materiality: are your climate risks / emissions material to investors?
  • California nexus: do you do business in California above the SB-253/261 thresholds?
  • Scope 3: the live regimes need it — is your value-chain data ready?
  • Assurance readiness: can your emissions data withstand limited (or reasonable) assurance?
  • Legal posture: consult securities counsel on filing exposure — this is reference, not advice

Error Traps — With Consequences

Error What happens Consequence How to avoid
Treating the rule as in force Building a compliance programme to file under a rule that is stayed and proposed for rescission. Effort against a non-obligation
No SEC climate filing is currently required; the live obligations are elsewhere (California, IFRS S2, CSRD).		 Confirm current status on SEC.gov; map obligations to the live regimes, not this rule.
Assuming all filers report emissions Applying Scope 1/2 disclosure across SRCs and EGCs. Over-states the rule’s reach
Only LAFs and AFs were in the emissions limb, and only where material; SRCs/EGCs were exempt.		 Gate the emissions limb to LAF/AF and to material emissions, per the rule as adopted.
Including Scope 3 as an SEC requirement Carrying Scope 3 from the 2022 proposal into the rule’s requirements. Wrong scope boundary
Scope 3 was dropped from the final rule entirely; only the live regimes (California, IFRS S2, CSRD) require it.		 The SEC final rule was Scope 1 & 2 only. Use California SB-253 / CSRD for the Scope 3 obligation.
Applying reasonable assurance to accelerated filers Projecting an AF onto the reasonable-assurance escalation. Mis-stated assurance burden
Reasonable assurance was LAF-only (FY2032); AFs cap at limited permanently.		 Reasonable assurance applies to large accelerated filers only; AFs phase in limited and stop there.
Assuming the stay killed all climate disclosure Concluding climate is irrelevant to SEC filings because the rule is stayed. Missed live obligations
Item 105 material-risk disclosure was never stayed; the financial-statement limb is separable; California is live.		 Material climate risk remains disclosable under existing securities law; check Item 105 and live regimes.
Quoting a “stay release” number that may not exist Citing an unverified release number for the April 2024 stay. Inaccurate citation
Cite the verified adopting release (33-11275) and the rescission proposal (33-11421); confirm any stay release on SEC.gov.		 Cite only release numbers you can verify on SEC.gov; describe the stay by date if unsure.
Calling the rule “rescinded” Describing a proposed rescission as a completed one. Overstates finality
As of June 2026 rescission is proposed with comment open — not final; the rule remains stayed, not formally rescinded.		 Say “proposed for rescission, comment period open”; re-check status before relying.

Methodology Metadata — For Reference Documentation

The rule-text values are reproduced from the rule as adopted; the status facts are from SEC releases and the Eighth Circuit docket and are newer than any static dataset. Verify current status on SEC.gov before relying on this page.

Methodology GreenCalculus SEC Climate Disclosure Rule Reference Methodology v1.1 (June 2026). greencalculus.com/methodology/sec-climate-disclosure-rule-methodology/
Rule as adopted SEC Release No. 33-11275 (companion 34-99678), “The Enhancement and Standardization of Climate-Related Disclosures for Investors”, adopted 6 March 2024.
Current status Voluntarily stayed 4 April 2024; SEC ended its defense 27 March 2025; Eighth Circuit held petitions in abeyance (Sept 2025); SEC letter to the court 7 May 2026; rescission proposed 29 May 2026 (Release 33-11421), comment period open. Rule not in force.
Emissions scope As adopted: Scope 1 and Scope 2 for large accelerated and accelerated filers, where material. Scope 3 dropped from the final rule. SRCs and EGCs exempt from emissions disclosure.
Assurance Limited assurance phasing in from year 3 (LAF FY2028 / AF FY2029); reasonable assurance from year 7 for large accelerated filers only (FY2032). Accelerated filers cap at limited.
Financial statements Subpart 1500 / Regulation S-X Article 14 — severe-weather effects and carbon-credit/REC costs in audited statements; thresholds 1.0% of capitalized costs and 0.01% of expensed costs. A separable, GAAP-audited limb.
Measurement basis Emissions on GHG Protocol principles — the rule added a disclosure/assurance wrapper, not a new accounting method. Item 105 material-climate-risk disclosure predates the rule and was not stayed.
Not legal advice Factual reference only. Filing-exposure decisions require securities counsel and current verification of regulatory status.
SEC Climate Disclosure Rule — GreenCalculus.com
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Does this regime apply to you? Scoping is a separate question from reporting, and the six regimes use six different size tests. For the thresholds side by side — revenue, public float, turnover, balance sheet and headcount — with first reporting years and assurance phase-ins, see Regulatory Thresholds.

Frequently Asked Questions

No. The rule was adopted on 6 March 2024 (Release 33-11275) but the SEC voluntarily stayed it on 4 April 2024 pending litigation, so it never took effect. The Commission voted to end its defense of the rule on 27 March 2025, and on 29 May 2026 it formally proposed to rescind the rule in its entirety (Release 33-11421), with a comment period open. As of June 2026 there is no SEC climate-disclosure filing obligation in force. The rescission is proposed, not completed — but the rule has been stayed throughout and was never operative. Always verify the current position on SEC.gov before making a filing decision.

Two limbs, both materiality-gated. First, narrative climate-risk disclosures — governance, strategy, risk management, and any climate targets or transition plan — echoing the four TCFD pillars. Second, quantitative financial-statement disclosures under Subpart 1500 / Regulation S-X Article 14 for severe-weather effects and carbon-credit/REC costs above set thresholds. Large accelerated and accelerated filers would additionally have disclosed Scope 1 and Scope 2 emissions where material, with third-party assurance phasing in. Scope 3 was dropped from the final rule. Smaller reporting companies and emerging growth companies were exempt from the emissions disclosure.

No. The 2022 proposal included Scope 3 where material or where the issuer had a Scope 3 target, but the final 2024 rule removed Scope 3 entirely in response to cost, reliability, and value-chain-data concerns. As adopted, the rule reached only Scope 1 and Scope 2, and only for large accelerated and accelerated filers where material. If you need to report Scope 3, the obligation comes from other regimes — California SB-253 and CSRD both reach Scope 3 — not from the SEC rule.

Only the two largest tiers. Large accelerated filers (public float of $700 million or more) and accelerated filers (float of $75 million up to $700 million) would have disclosed Scope 1 and Scope 2 emissions where material. Smaller reporting companies (float under $250 million, or revenue under $100 million with float under $700 million) and emerging growth companies (revenue under $1.235 billion within the time-limited window) were exempt from the emissions disclosure, though the narrative climate-risk items would still have applied to them. The common summary that “the SEC required all public companies to report emissions” overstates the rule’s reach on two counts: it was tier-limited and materiality-gated.

Yes, and the difference is frequently mis-stated. Both large accelerated and accelerated filers would have phased in limited assurance over their Scope 1 and Scope 2 disclosure from the third year of reporting (FY2028 for LAFs, FY2029 for AFs on the original schedule). Only large accelerated filers would then have escalated to reasonable assurance — the higher, positive-opinion level used for audited financial statements — from the seventh year (FY2032). Accelerated filers were never going to advance past limited assurance. All of these dates were stayed before taking effect.

It can. Two things outlived the stay. Item 105 of Regulation S-K already required disclosure of material risk factors, including material climate-related risks, before this rule existed and was never part of the stay — so material climate risk remains a live disclosure consideration under existing securities law. Separately, the rule’s financial-statement provisions (Subpart 1500 / Regulation S-X Article 14) are a structurally distinct, GAAP-audited limb. The practical point is that the stay of the climate rule does not mean climate is irrelevant to SEC filings — and quite apart from the SEC, California SB-253/261 imposes live obligations on many of the same issuers.

Map your live obligations to the regimes that are in force, not to the stayed SEC rule. California SB-253/261 is the most consequential — SB-253 requires Scope 1, 2, and 3 for companies doing business in California above $1 billion revenue, and it is live. US groups with EU operations may fall under CSRD ESRS E1; those with UK entities may face UK TCFD-aligned disclosure or SECR; and investor demand for IFRS S2-aligned data continues regardless of mandate. Underneath all of them is a GHG Protocol inventory — building that is the work that carries across every regime, including a future US one.

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