SBAI Responds to SEC - Climate Change Disclosures

SBAI responds to SEC’s Request for Public Input on Climate Related Disclosures focusing on standardisation, global consistency, ESG beyond climate, proportionality, and sequencing.

Whilst this consultation related to disclosure by issuers, we responded with several key points that should govern any regulatory approach to ESG disclosures:

  • Making use of existing ESG disclosure frameworks
  • Ensuring global consistency of disclosure requirements
  • Considering other ESG risks in addition to climate
  • Proportionality of requirements
  • Sequencing and Implementation – dis.closure should be mandated at the issuer level before the asset manager level