In March 2022, the SEC proposed climate-disclosure rules. I originally wrote as if the requirements were already in force. They were a proposal, and the difference matters.
I wanted companies to explain climate risks in the same filing as other material business risks. That would make it harder to bury a flood-exposed warehouse or a supply chain tied to drought in a glossy sustainability report. The hard part was deciding which emissions data companies could measure reliably and how much reporting cost smaller issuers should bear. I would judge the rule by whether investors got comparable, decision-useful information, not by the length of the disclosure.