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Review of Comments on SEC Climate Rulemaking

Harvard Corporate Governance

suggested that “Scope 3 implementation should be delayed to 2027” (see also Center for Sustainable Business at the University of Pittsburgh ). The potentially adverse effect of Scope 3 disclosures on smaller entities was highlighted.

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Sullivan & Cromwell Discusses the Implications for Financial Institutions of Proposed SEC Climate Disclosure Rules

Reynolds Holding

These metrics would then be subject to audit by an independent registered public accounting firm and come within the scope of the institution’s internal control over financial reporting. Fiscal year 2026 (filed in 2027). Fiscal year 2027 (filed in 2028). ( [1] ) Assumes a fiscal year end of December 31. filed in 2024).