Billy Berler, billy.berler@sierraclub.org
WASHINGTON, D.C. — As the public comment period closes today on the Securities and Exchange Commission’s proposal to rescind its 2024 climate disclosure rule, the Sierra Club submitted and joined multiple filings opposing the rollback. These include an organizational comment, a grassroots submission backed by more than 2,000 Sierra Club members and supporters, and two coalition comment letters addressing the proposal’s legal and financial-market implications.
During the comment period, the Sierra Club submitted or joined:
- An organizational comment urging the SEC to withdraw the rescission proposal and incorporating two comments Sierra Club submitted with partners during the agency’s original 2022 rulemaking. The filing emphasizes that climate-related risks are financially material, investors have long demanded consistent and decision-useful information, voluntary reporting has failed to provide adequate comparability, and the SEC has clear statutory authority to require standardized disclosures. Although Sierra Club advocated for stronger requirements than those ultimately included in the 2024 final rule, the comment states that the rule established an important federal baseline that should be retained and implemented.
- A grassroots comment signed by more than 2,000 Sierra Club members and supporters, calling on the SEC to preserve standardized climate-related disclosures and warning that rescission would make it harder for investors to compare companies, evaluate long-term risks, and allocate capital efficiently.
- A legal comment filed with Earthjustice, Environmental Defense Fund, Clean Air Task Force, and Natural Resources Defense Council, arguing that the climate disclosure rule falls well within the SEC’s statutory authority and that the proposed rescission misreads the law, disregards the growing evidence of financially material climate risks, and is legally and factually unsupported.
- A coalition comment led by Americans for Financial Reform Education Fund and Public Citizen and joined by Sierra Club and dozens of other organizations, highlighting accelerating climate-related financial risks, overwhelming investor support for standardized climate disclosure, and the market failures that make mandatory reporting necessary.
Together, the filings argue that climate-related financial risks are growing, investors need standardized and comparable information to assess those risks, and the SEC has both the authority and responsibility to preserve meaningful disclosure requirements.
In response, Jessye Waxman, Sustainable Finance Campaign Advisor with the Sierra Club, issued the following statement:
“The SEC is choosing politics over investors. Investors have spent more than a decade asking for consistent, comparable climate-related information because climate risk is financially material. By proposing to rescind this rule, the SEC is abandoning its responsibility to protect investors and maintain fair, orderly, and efficient markets. Markets cannot allocate capital efficiently when investors lack material information. Climate disclosure isn't just about transparency; it's about ensuring capital flows to companies managing long-term financial risks rather than obscuring them. Rescinding this rule won't make climate risk disappear; it will just make markets less efficient, increase the mispricing of risk, and undermine investment in the resilient economy we need.”
BACKGROUND
In March 2024, the SEC adopted the final rule, formally titled “The Enhancement and Standardization of Climate-Related Disclosures for Investors.” The rule was designed to provide investors with standardized, comparable information about financially material climate-related risks, including physical risks from climate impacts and transition risks facing companies as the economy shifts. The final rule was weaker than the original proposal, including the removal of Scope 3 emissions disclosure requirements.
The rule has not taken effect due to legal challenges from industry groups and their political allies. In April 2024, the SEC stayed the rule pending judicial review. In August 2024, the Sierra Club and other organizations submitted an amicus brief in the Eighth Circuit defending the SEC’s authority to issue the rule. In February 2025, then-Acting Chair Mark Uyeda requested that the Eighth Circuit pause scheduled arguments while the Commission considered its position; in March 2025, the Commission voted to end its defense of the rule; and in July 2025, the SEC stated that it would not review or reconsider the rule at that time and urged the court to allow the legal challenge to proceed. The court instead kept the case in abeyance, and in May 2026 the SEC formally proposed rescinding the rule in full. The public comment period on that proposal closes today.
During the original rulemaking process, investors overwhelmingly supported federal climate disclosure requirements. According to an analysis by Ceres, hundreds of institutional investors — representing tens of trillions of dollars in assets under management — commented with near-unanimous support for standardized climate-related disclosures, including greenhouse gas emissions reporting.
As states and major global jurisdictions continue moving forward with climate disclosure requirements, rescinding the SEC rule would abandon the prospect of a consistent federal baseline for U.S. public companies.
About the Sierra Club
The Sierra Club is America’s largest and most influential grassroots environmental organization, with millions of members and supporters. In addition to protecting every person's right to get outdoors and access the healing power of nature, the Sierra Club works to promote clean energy, safeguard the health of our communities, protect wildlife, and preserve our remaining wild places through grassroots activism, public education, lobbying, and legal action. For more information, visit www.sierraclub.org.