On March 21, 2022, the US Securities and Exchange Commission (SEC) voted 3:1 to propose new rules that, if adopted, would require public companies to, among other things, provide audited financial statements containing climate-related financial impact and expenditure metrics, report their greenhouse gas emissions, and disclose details of how climate change is affecting their businesses. This proposal signifies a substantial change to existing law and, if adopted, would have wide-ranging implications for companies’ disclosure requirements and internal procedures. This Legal Update provides further detail on the proposal and discusses potential arguments litigants may advance to challenge it.