This updated report provides a roadmap for improving environmental, social, and governance (ESG) disclosures related to environment and climate change risks and opportunities. This guidance is based on an analysis of Securities and Exchange Commission (SEC) comment letters that were sent to 10-K and 20-F annual report filers from July 2021 to January 2023.

While regulations and the investor landscape around ESG are evolving, those companies that are already providing information regarding the environment and climate change in their publicly posted environmental/sustainability/ESG reports, corporate social responsibility (CSR) reports, and other website reports need to pay particular attention to the nature of information disclosed in these reports and the interaction with their annual SEC report filings.

Using data from the CompanyIQ Comment Letters research tool, this paper identifies 11 climate-related comment letter themes that U.S. public companies should pay close attention to in anticipation of SEC climate change disclosure regulations expected this spring.