Overview
In March 2024 the US Securities and Exchange Commission adopted climate-related disclosure amendments for registration statements and annual reports. Those rules were stayed on 4 April 2024 pending consolidated litigation in the Eighth Circuit.
After ending its defence of the rules in 2025, the SEC on 29 May 2026 proposed to rescind them in full. The proposal was published in the Federal Register on 3 June 2026, with comments due by 3 August 2026.
Until the Commission adopts a final rescission (or otherwise revises its position), the 2024 rules are not being implemented. Fashion issuers subject to SEC reporting should monitor the rulemaking and continue to consider investor, state and international climate disclosure expectations.
Sources: SEC Release 33-11421; SEC press release 2026-49.
Key requirements
- As adopted in 2024 (currently stayed): governance, strategy, risk management and climate metrics disclosures, plus certain financial-statement effects.
- Current practical status: no operative SEC climate-rule compliance calendar while the stay and rescission proposal are pending.
- Issuers may still face climate disclosure pressure from investors, California SB 253/261 and non-US regimes such as CSRD.
Who’s affected
SEC registrants, including listed fashion and retail companies. State and foreign disclosure laws may still apply even if the federal climate rules are rescinded.
Timeline
6 March 2024
SEC adopts final climate disclosure rules.
4 April 2024
Commission stays the rules pending litigation.
29 May 2026
SEC proposes full rescission (Release 33-11421 / File S7-2026-19).
3 August 2026
Public comment deadline on the rescission proposal.
How Carbon Trail helps
Compliance Assistance
- Carbon Trail provides support to fashion brands in navigating the complexities of the SEC Climate Disclosure Rules, from data collection to reporting.
Services for sustainability reporting
- Carbon Accounting: Accurate measurement of emissions.
- Product Life Cycle Assessment (LCA): Life Cycle Assessment for product sustainability.
- Digital Product Passports: Comprehensive product data for transparency.
- Decarbonization Services: Strategies to reduce carbon footprints.
Frequently asked questions
Are SEC climate disclosures required for the 2026 reporting season?
No operative compliance dates are running under the stayed 2024 rules. Watch the rescission rulemaking for a final Commission vote.
