This paper provides an update on ESG disclosures, more specifically environment and climate-related risks and opportunities. This analysis is based on a review of Securities and Exchange Commission (SEC) Comment Letters that were sent to U.S. public companies from July 2021 to May 2024. Our original December 2022 report covered July 2021 to January 2023 data. This update covers an additional 14 months of of data February 2023 to May 2024.

Using the MyLogIQ CompanyIQ SEC Comment Letters database, we found that:

  • the SEC is focused on 18 broad climate-related themes – seven more than our prior report;
  • there are seven climate-related reporting sub-themes based on the physical effects of severe weather impacts, including quantification, consistency in financial statements, and determination of materality; and
  • companies should consider the downstream and upstream impacts of climate-related severe weather events.

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