The SEC Just Moved to Rescind Its Climate Rule: What US-Listed Groups Should Do Now

The Securities and Exchange Commission's proposed rescission of its 2024 climate-related disclosure rule closed for public comment on 3 August 2026. All three sitting Commissioners support full rescission, the SEC has withdrawn its defence of the rule in the Eighth Circuit litigation, and the Federal Register publication in June leaves the SEC on a fast track to finalise the rescission in the autumn. For US-listed groups that built systems to comply with the rule, the practical question is not whether the rule survives, it is what to do with the infrastructure already built.1

Last updated 9 August 2026. Reflects the SEC rescission proposal published in the Federal Register on 3 June 2026 and the close of the comment period on 3 August 2026.

Key takeaways. The SEC proposed on 29 May 2026 to rescind in full its 2024 climate-related disclosure rules. The proposal was published in the Federal Register on 3 June 2026; the public comment period closed 3 August 2026. All three sitting Commissioners support full rescission. Absent a change of position, the SEC is on track to finalise the rescission in the autumn of 2026. US-listed groups that built the data infrastructure to comply are not out of scope: California SB 253 catches them from 2026 (Scope 1 and 2) and 2027 (Scope 3); CSRD catches those with material EU operations from 2028 (delayed cohort); ISSB IFRS S1/S2 is being adopted by 30-plus jurisdictions and expected by investor coalitions representing US$120tn AUM. The infrastructure built for the SEC rule maps almost one-for-one onto ISSB S2, a discipline lift, not a wasted asset.

What did the SEC actually propose, and when?

The proposal is a full rescission, not a narrower alternative. On 29 May 2026 the SEC voted 3-0 to propose rescinding in full the climate-related disclosure rules adopted in March 2024. The rules had been immediately stayed on adoption pending consolidated Eighth Circuit litigation. The SEC withdrew its defence of the rule in the litigation earlier in 2026, and the rescission proposal is the formal end of that regulatory chapter.1,2

The comment window was 60 days. Published in the Federal Register on 3 June 2026, comments closed 3 August 2026. Investor groups, environmental NGOs and some Democrat-aligned attorneys general filed comments opposing rescission; the majority of comments from corporates and industry associations either supported rescission or urged narrower alternatives (rescission of specific provisions, retention of Regulation S-K-based governance and risk disclosure, or a de minimis threshold to shelter smaller filers).

Figure 1. Timeline of the SEC climate rule, from proposal in 2022 to rescission in 2026.
Mar 2022 Mar 2024 Apr 2024 May 2026 Aug 2026 Rule proposed Rule adopted (party-line) Rule stayed (Eighth Circuit) Rescission proposed Comment period closed Green = adopted, amber = stayed, dark amber = rescission process. Rule was in force for approximately zero business days.

If we already built the infrastructure, is the work wasted?

No. The systems, data and governance built to comply with the SEC rule, GHG emissions inventory, scenario analysis, climate risk taxonomy, disclosure controls, map almost one-for-one onto the standards that continue to apply to US-listed groups from other jurisdictions. The chart below shows how the SEC rule's four disclosure blocks translate into ISSB IFRS S2, CSRD ESRS E1, and California SB 253/261.

Disclosure element Was in SEC rule ISSB IFRS S2 CSRD ESRS E1 California (SB 253/261)
Governance of climate risk Yes Yes Yes SB 261
Climate risk strategy & scenario analysis Yes Yes Yes SB 261
Scope 1 & 2 GHG emissions Yes Yes Yes SB 253
Scope 3 GHG emissions Optional Yes Yes SB 253 (2027)
Financial impact quantification Yes Yes Yes Narrative
External assurance Yes Varies Yes From 2030

Which US-listed groups are still caught by a climate rule?

Most of them. The rescission of the SEC rule reduces the number of federal-level disclosure obligations to zero for the moment, but it does not remove US-listed groups from every other climate rule now on the books. The chart below shows the overlap.

Figure 2. Estimated overlap of climate reporting obligations for US-listed groups, post-SEC rescission. Almost every US-listed group above US$500m revenue is now subject to at least one non-SEC climate disclosure regime.
California SB 253 (Scope 1&2) California SB 261 (risk report) CSRD (EU material operations) ISSB (adopting jurisdictions) UK SRS S1/S2 (FCA listed) Investor coalitions (voluntary) None of the above ~5,300 ~10,000 ~2,600 ~4,400 ~900 US$120tn AUM rare

Approximate counts. Figures are directional estimates from public regulatory impact assessments and industry analyses; no single authoritative source publishes a unified count of US-listed groups caught by each regime. Investor coalition figure = combined AUM of signatories to CDP, TCFD, Climate Action 100+ and similar. Overlap is substantial: a US-listed FTSE Global 250 name with EU sales and California customers is caught by all four.

What US-listed groups should actually do now

The pragmatic response to the SEC rescission is not to switch off the climate reporting programme. It is to redirect it. Six moves make the difference between "wasted preparation" and "compounding infrastructure."

  • Redirect the disclosure controls to voluntary ISSB S2 filing. Every governance, controls, and financial-impact process built for SEC compliance maps onto ISSB S2. A voluntary ISSB filing gives you investor-recognised disclosure without waiting for a new US federal rule.
  • Map California SB 253 and SB 261 obligations at group level. Any US-listed group above US$1bn global gross revenue that does business in California owes SB 253 emissions from 2026, Scope 3 from 2027. The SEC rescission does not touch this.
  • Assess CSRD exposure via EU subsidiaries and branches. A US-listed parent with a material EU subsidiary (Wave 2 or Wave 3 caught, or a large branch generating €150m+ EU turnover) will still owe CSRD.
  • Keep the assurance readiness on track. ISSA 5000 limited assurance is now the international norm for sustainability disclosures. A group that built the evidence trail for SEC-style limited assurance is ahead of the pack for ISSA 5000.
  • Meet investor coalition expectations. Even without a mandatory US federal rule, CDP, TCFD-aligned voluntary reporting, and Climate Action 100+ continue to be requested by the largest US and global asset managers. The rescission does not remove investor-driven disclosure.
  • Communicate the redirection. Boards and audit committees that green-lit the SEC compliance programme need a briefing on how the work is being redirected, not abandoned. The narrative matters as much as the mechanics.
The infrastructure isn't wasted. Every dollar spent on GHG inventory, scenario analysis, climate risk taxonomy and disclosure controls between 2024 and 2026 becomes ISSB S2 infrastructure. The SEC rule was in force for zero business days. The systems built to comply with it are in force for the next decade.

Frequently asked questions

When did the SEC propose to rescind its climate disclosure rule?

The SEC voted to propose rescission on 29 May 2026 with the support of all three sitting Commissioners. The proposal was published in the Federal Register on 3 June 2026, opening a 60-day public comment period that closed on 3 August 2026.

Is the SEC climate rule still in force?

No. The rule was adopted in March 2024 and immediately stayed pending Eighth Circuit litigation. It has never taken practical effect. The SEC has withdrawn its defence of the rule and moved to rescind it in full. Absent a policy reversal, formal rescission is expected in the autumn of 2026.

Do US-listed groups still have climate disclosure obligations?

Yes, from other regimes. California SB 253 requires Scope 1 and 2 disclosure from 2026 for US groups above US$1bn revenue. SB 261 requires a climate-related financial risk report for groups above US$500m. CSRD catches US-listed groups with material EU operations from 2028 (delayed Wave 2/3 cohorts). ISSB IFRS S2 is adopted or in progress in 30-plus jurisdictions. Investor coalitions representing US$120tn AUM continue to request climate disclosure.

Does the SEC rescission affect existing GHG emissions inventories?

No, the underlying systems, data and governance built for SEC compliance map almost one-for-one onto ISSB IFRS S2. Groups that built the infrastructure can redirect it to voluntary ISSB S2 filing, CSRD compliance (where applicable) or California disclosure without material rework.

What happens if a group is caught by both California SB 253 and CSRD?

Both regimes apply. A US-listed group above US$1bn revenue with material EU operations owes SB 253 emissions disclosure to CARB on the California timeline (2026 Scope 1&2, 2027 Scope 3) and CSRD sustainability statements to its EU statutory auditor on the EU timeline. The underlying GHG inventory and scenario analysis feeds both, one dataset, two filings.

Are voluntary investor-driven disclosures still relevant after the rescission?

Yes. CDP, TCFD-aligned voluntary reporting, and Climate Action 100+ engagement continue to be requested by the largest US and global asset managers regardless of federal rule status. Investor coalition AUM signatories total roughly US$120 trillion. A US-listed group ignoring investor-driven disclosure risks capital access, not compliance penalties.

Could the SEC rescission be challenged in court?

Yes. Investor groups, environmental NGOs and Democrat-aligned state attorneys general filed comments opposing rescission and have signalled intent to challenge the final rule on Administrative Procedure Act grounds. The rescission proposal is expected to be finalised in the autumn of 2026; litigation could delay effective date but is unlikely to reinstate the original rule.

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References

  1. Securities and Exchange Commission, Press release: SEC Proposes Rescission of Climate-Related Disclosure Rules, 29 May 2026.
  2. Federal Register, Rescission of Climate-Related Disclosure Rules, 3 June 2026.
  3. K&L Gates, SEC Proposes to Rescind Climate Disclosure Rules, July 2026.
  4. Gibson Dunn, SEC Proposes Rescission of Climate-Related Disclosure Rules, June 2026.

This guide is general information, not legal advice. The rescission process is ongoing at the date shown; check the primary sources above for the current position.

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