This document constitutes supplemental comments of the Center for Climate and Energy Solutions (C2ES) regarding an alternative to the proposed regulation S-X provisions in the proposed rule by the Securities and Exchange Commission (SEC) on climate-related financial disclosures, “The Enhancement and Standardization of Climate-Related Disclosures for Investors.” These comments represent a synthesis of information and feedback we received from members of the C2ES Business Environmental Leadership Council (BELC) as part of a [virtual] convening C2ES held in January 2023.

C2ES is an independent, nonprofit, nonpartisan organization whose mission is to secure a safe and stable climate by accelerating the global transition to net-zero greenhouse gas emissions and a thriving, just, and resilient economy.