C2ES supports mandatory climate-related financial risk disclosure, and believes that the proposed rule can play a vital role in helping the broader investor community gain better insights into how all publicly traded companies are managing their climate-related financial risks.  

In these comments, we identify a number of elements of the proposed rule that we strongly agree with. We also highlight where improvements are needed for this rule to be operational and effective. In particular, several provisions not raised in the SEC’s 2021 request for input have been introduced that present challenges for implementation and compliance.  

Throughout our responses to the SEC’s questions our intention is to support the proposed rule’s broader aim to create greater transparency, consistency, and comparability of climate-related financial risks across publicly traded companies. We also note where the SEC can engage with other government entities and the expert stakeholders to stay in step with new developments in science, data availability, and other climate-related disclosure standards.