Integrate Proposed SEC Climate Disclosures and ESG With Data Analytics

On March 6, 2024, the SEC issued a final rule requiring registrants to disclose climate-related information in their registration statements and annual reports. See additional details in the alert, SEC Finalizes Climate Disclosure Rule, published March 12, 2024.

The proposed SEC climate-related disclosure rule requires both domestic and foreign registrants to disclose a variety of climate-related information in registration statements and annual reports.

Explore how to integrate environmental, social, and governance (ESG) climate-related data into existing or new data analytics platforms to streamline your reporting process.

What Is the Proposed SEC Climate Disclosure Rule?

The proposed SEC climate disclosure requirements would standardize climate disclosures provided by public companies. Specifically, the disclosures companies would need to provide include an accounting of their greenhouse gas (GHG) emissions, the environmental risks they face, and the measures they’re taking in response.

These would focus on climate-related risks likely to have a material impact on the organization or the organization’s financial statements. The disclosures would require organizations to describe the actual and potential impacts of climate-related risks on the strategy, business model, and outlook.

What Is ESG Reporting?

ESG reporting addresses how organizations disclose their operations in three areas: environmental, social, and corporate governance, all of which bring transparency to a company’s ESG activities.

What Does Each ESG Area Represent?

ESG stands for environment, social, and governance.


The environmental area measures how companies use and manage energy, which include energy efficiency, climate change impacts, carbon emissions, waste management, and air and water quality.

The Greenhouse Gas (GHG) Protocol, a widely accepted standard for accounting for greenhouse gas emissions, has categorized emissions into three scopes:

  • Scope 1. Direct emissions from the organization’s owned or controlled sources.
  • Scope 2. Indirect emissions from generating purchased electricity, steam, heating, and cooling that the organization consumes.
  • Scope 3. All other indirect emissions from a company’s value chain as well as 15 categories of common business activities.


The social area measures how an organization promotes its people and culture. Factors that are often addressed include:

  • Inclusivity
  • Gender
  • Diversity
  • Employee engagement
  • Human rights
  • Labor standards


The governance area addresses the organization’s internal control structure which ensures transparency with regulations.

What Data Is Required in the Proposed SEC Climate Disclosure Rule?

The climate disclosures would need to include information such as the following:

  • Management’s role in assessing and managing climate risks
  • Oversight and governance of climate-related risks
  • Scope 1 and Scope 2 greenhouse gas emissions—and Scope 3 indirect value chain emissions—if a GHG emission reduction target has been defined
  • Impacts of past and present climate-related risks on the business and financial statements
  • Climate targets, goals, and transitions plans
  • Price and rationale for internal carbon prices

Organizations should automate their data integration as it relates to climate metrics and develop a governance and control structure over the source, transmission, and presentation of data, ideally using their existing financial control structure over climate-related data. Data process flows and any data transformations should also be documented.

What Are the Steps to Prepare for Climate Disclosure Reporting?

Organizations would need to decide where their ESG reporting function lives, as this team will not only be responsible for reporting metrics but also overseeing the control and reliability of ESG data.

Organizations will also need to clearly define:

  • ESG metrics
  • What ESG metrics include
  • In which systems or applications this data resides
  • Who owns the metrics

Once defined, organizations should gather their existing data to create a baseline to evaluate future performance. Organizations should use this reporting exercise to ensure compliance with regulatory requirements and integrate the information gained into their overall business strategy.

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If you’re curious about how to approach your data analytics strategy or SEC climate disclosures, reach out to your Moss Adams professional.

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