In a comment letter to the Securities and Exchange Commission on June 11, seven well-known tech companies responded to SEC Acting Chair Allison Herren Lee’s March 2021 request for public input on climate change disclosures (see our related blog post). The letter expressed support for consistent reporting by public companies regarding climate-related matters.

With acknowledgement regarding the severity and urgency of addressing climate change issues, the letter mentions that the companies believe “…it is critical to regularly measure and report on progress towards climate commitments.”  The letter notes the importance of sharing updates with investors and stakeholders, stating, “Investors need clear, comprehensive, high-quality information on the impacts of climate change for market participants.”

The letter addressed to Chair Gensler specifically outlined some climate disclosure suggestions for the SEC to consider, including:

  • Relying on a flexible principles-based framework to align with agendas that already have, or will have, common support from investors, such as those of the Task Force on Climate-Related Financial Disclosures (TFCD);
  • Leveraging existing SEC frameworks and standards for climate reporting in order to reduce companies’ “reporting burden,” while also implementing a comment period for the public in an effort to limit the need for frequent substantive deliberations;
  • Including disclosure of greenhouse gas emissions information to divulge companies’ emissions footprint, thus allowing reflection on globalized standards; and
  • Allowing separate reporting location, frequency, and timing, especially outside of the current boundaries of documents that are filed with the SEC annually and quarterly.

These companies are already taking measures to report on their environmental performance and would like to see a consistent standard set across the board.

Read the response letter in its entirety here.