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SEC proposed climate disclosure rule

The Securities and Exchange Commission (SEC) has introduced a transformative climate disclosure rule aimed at revolutionizing the reporting landscape for public companies. 

This proposed rule seeks to mandate detailed disclosure of emissions, climate risks, and strategies for achieving net zero emissions, marking a significant leap towards corporate transparency and sustainability. 

Key Aspects of the Proposed Rule

At the core of the SEC’s proposed rule lies a call for comprehensive reporting, compelling companies to provide detailed insights into their climate-related facets. This includes the delineation of risks associated with climate impact, emissions data, and robust plans for achieving net zero emissions.

One of the primary objectives of the SEC’s proposal is to arm investors with consistent, comparable, and meaningful climate-related information. This will enable investors to make more informed decisions, considering a company’s environmental impact and climate risk profile in their investment strategies.

Moreover, standardizing reporting obligations across companies issuing securities is another key aspect of the proposal. This seeks to establish uniformity in disclosures, potentially reducing discrepancies and enhancing the overall quality of information provided by companies.

Most notably, SEC’s proposed rule will significantly impact the practices of accounting, auditing, and assurance for public companies and their service providers. It involves adapting existing frameworks to accommodate the new reporting requirements

It may also call for developing new methods and standards for evaluating and reporting climate-related information. 

Overall, the proposed climate disclosure rule cover two major aspects:

  • Climate-Related Financial Impacts: The regulation tackles how climate-related impacts should be included in financial statements (e.g. balance sheet, income statement, cash flow).
  • Narrative Disclosures: The rule also involves narrative disclosures in form SK. It will likely include discussions on risks, business strategy impacts, and metrics like greenhouse gas inventory.

Implications and Challenges for Companies

The SEC’s disclosure rule also poses a number of implications and challenges. 

The first one is increased reporting obligations for companies. They will face additional reporting demands that may require thorough data gathering, accurate presentation, and strengthened internal controls to comply with the new regulations. 

Companies also have to go along the transition from voluntary to regulated disclosure. This represents a significant change, requiring gradual efforts until they become accustomed to the new reporting requirements. 

However, for companies that are already complying with similar disclosure rules, it would be easier for them to embrace the proposed changes. Given the overlap with other existing regulations, determining the costs of the SEC’s rule alone would be hard. 

But according to the SEC, the required reporting will cost a small publicly listed firm about $420,000 a year on average. For a larger company, it will be $530,000 a year.

SEC climate disclosure rule cost
Source: U.S. SEC

Role of Carbon Credits and RECs

The SEC’s proposed rule acknowledges the relevance of carbon offsets and renewable energy credits (RECs), underlining their importance in climate-related reporting. Companies increasingly leverage these instruments for decarbonization, establishing  market-based mechanisms to advance sustainability goals.

However, discussions have emerged regarding the adequacy of the SEC’s requirements, raising concerns about the need for more comprehensive disclosures. It’s crucial for investors and stakeholders to understand how the use of these credits impacts a company’s risk profile, business strategy, and long-term financial implications. 

In particular, the proposed rule outlines the following key areas for disclosure:

  • Climate-Related Risk: Companies’ use of voluntary carbon markets in their transition risk strategy.
  • Business Strategy Alignment: How the use of carbon credits or offsets aligns with a company’s business model, strategy, and future outlook.
  • Targets and Goal Disclosure: Requirements for companies to disclose if their sustainability targets involve the utilization of RECs and offsets.

While the proposed rule has been in existence for about 18 months, awaiting finalization, stakeholders have actively engaged in the process, submitting over 20,000 comments during a consultation period. 

However, the final timeline for its completion remains uncertain, leaving companies in a state of anticipation regarding the impending changes.

How to Prepare for SEC’s Proposed Climate Disclosure Rule: A Roadmap for Companies

Despite the uncertain timeline, companies are advised to prepare by focusing on “no regret” actions, according to Matt Handford, Principal, Climate Change and Sustainability at Ernst & Young. He further shared insights on how companies can better prepare for the new disclosure requirements. 

Key areas to focus on per Handford’s advice include the following:

Emissions Understanding and Accounting: 

Companies need to treat emissions data with the same rigor as financial data, ensuring completeness, accuracy, and reasonableness of their emissions inventory.

Data Hygiene and Quality Assurance: 

Emphasis should be on the quality of data and the reliability of sources, underpinning robust documentation and validation processes.

Reassessment of Climate-Related Claims: 

Companies are reassessing their public claims related to carbon neutrality and net zero targets, ensuring robust strategies and execution plans to meet these objectives.

Engaging Internal Stakeholders: 

Collaboration across various internal departments, including finance and legal, is pivotal to comprehensively address climate-related disclosures and strategies.

The SEC’s proposed climate disclosure rule represents a transformative era in corporate reporting, mandating transparency and accountability regarding climate-related information. As businesses gear up for these regulatory changes, thorough preparation and collaborative approach will be crucial in meeting the evolving disclosure obligations and steering towards a more sustainable future.

The post A Deep Dive into SEC’s Proposed Climate Disclosure Rule for Sustainability appeared first on Carbon Credits.

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Carbon Footprint

Insetting vs Offsetting: Which Actually Counts Toward Your Scope 3 Targets

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The accounting differences that decide whether your nature investment shows up in inventory, in BVCM, or nowhere at all.

The question reaches a procurement team about three weeks before the next sustainability committee meeting. Someone has read about insetting. Someone else has just signed off on an offset purchase. The CSO wants to know if the two are interchangeable. The answer is no, and the GHG Protocol Land Sector and Removals Standard is the reason why.

This article walks through what each term means at audit-grade specificity, what the standards actually say about how each gets counted, and how to decide which tool fits which target. The insetting vs offsetting question is one of the most-searched in corporate climate strategy, and one of the most poorly answered. By the end of this piece, you should be able to brief a committee on the difference without notes.

The two definitions, in plain English

Offsetting means buying carbon credits generated outside your value chain and retiring them against your residual emissions. The reduction happens somewhere else, financed by you, and the credit is the receipt.

Insetting means investing in emission reductions or removals inside your own value chain, typically with suppliers, where the reduction is directly linked to the products and services you buy. The reduction happens inside the boundary of your Scope 3 inventory, and the accounting treatment is fundamentally different.

The shorthand from the University of Oxford’s Nature-based Insetting Initiative is useful: insetting is what you do with the supply chain you have; offsetting is what you do with the supply chain you do not have.

What the GHG Protocol Land Sector Standard actually says

The GHG Protocol Land Sector and Removals Standard, finalised in 2024 after a multi-year pilot, sets the rules for how land-based emission reductions and removals enter corporate inventories. The Standard distinguishes between inventory accounting (Scope 1, 2, and 3) and project or intervention accounting (a separate methodology for crediting).

For insetting, the practical implication is that supplier-level interventions, when properly measured and attributed, can reduce your Scope 3 category 1 (purchased goods and services) emissions in your inventory. The reduction is not a credit retired against the inventory; it is a lower inventory number, period.

For offsetting, the credit is retired separately. It can be reported as a contribution toward a net-zero claim under the SBTi Beyond Value Chain Mitigation framework or as part of a VCMI Carbon Integrity claim, but it does not lower the inventory number.

A practical consequence: if your Science Based Target requires a 50% absolute reduction in Scope 3 emissions by 2030, insetting moves you toward the target. Offsetting does not. This single point of difference reshapes the procurement decision.

When insetting counts toward Scope 3 (and when it does not)

Insetting counts toward Scope 3 only when several conditions are met:

  • The intervention must occur with an entity in your value chain.
  • The emissions reduction or removal must be measured against a defensible baseline.
  • The reduction must be attributed to your share of that supplier’s output, not double-counted with other buyers.
  • It must follow the inventory accounting rules in the GHG Protocol Land Sector Standard, not the project accounting rules used to generate credits.

The most common failure mode is double counting. If your supplier sells the same reduction as a credit on the voluntary market and also reports it to you as a Scope 3 reduction, the math breaks. The Standard requires you to address this risk, typically by purchasing and retiring the supplier-issued credit as part of your inventory or by contractual provisions that prevent the supplier from selling the reduction twice.

When insetting does not count toward Scope 3: when the intervention sits with a supplier you do not buy from, when the baseline is not defensible, when the attribution is unclear, or when the documentation does not survive audit. Those cases default to Beyond Value Chain Mitigation, which is still useful but operates on a different ledger.

The procurement and supplier engagement question

Insetting is harder than offsetting. That is the unfashionable truth most buyers eventually confront. Offsetting is a transaction; insetting is a relationship.

To run an insetting program, you need supplier mapping precise enough to know which farms or facilities sit at which Scope 3 boundary. You need an engagement model that gets suppliers to participate, which usually requires multi-year commitments and shared economics. You need an MRV architecture that measures the right things and produces audit-ready documentation. And you need a contractual structure that prevents double counting and protects both sides.

The trade-off you receive in return is significant. Reductions count against your inventory rather than your residual. Supplier relationships deepen, which protects sourcing continuity. Yield and quality improvements often follow regenerative interventions, which reduces your input cost over time. And the regulatory file, under CSRD, CSDDD, EUDR, and the SBTi FLAG Guidance, is materially stronger.

Choosing the right tool for the right target

A practical decision rule. If your target is a science-based Scope 3 reduction and you operate in a FLAG sector or source FLAG commodities, insetting is the structurally correct tool. If your target is a net-zero claim that includes neutralising hard-to-abate residual emissions outside your value chain, BVCM via high-integrity offsets is the structurally correct tool. Most companies with material Scope 3 exposure need both, in different proportions, sequenced over time.

The sequencing matters. Insetting takes longer to stand up but produces a permanent reduction in the inventory. Offsetting can be transacted faster but does not change the inventory and now sits under tighter claim restrictions. Treat them as complementary tools with different jobs, not as substitutes. The Accountability Framework Initiative and the IUCN Global Standard for Nature-based Solutions both provide useful guardrails for the insetting side, with biodiversity, human rights, and benefit-sharing requirements that go beyond carbon math.

If you are mapping a Scope 3 reduction roadmap and need to scope which interventions count toward your inventory versus which sit in Beyond Value Chain Mitigation, the carbon and sustainability experts at Carbon Credit Capital can help you structure a nature-based supply chain investment program that fits your FLAG exposure, your target architecture, and your audit horizon. Schedule a consultation.

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Carbon Footprint

Net zero needs nature: a carbon credit guide

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Net zero is often described as a balancing act: cut what you can, account for the rest, and reach zero on the ledger. That framing is useful, but it leaves something out. It treats every tonne of carbon as interchangeable and every route to zero as equally sound, while the science tells a more specific story.

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Carbon Footprint

Deforestation in Malawi: causes and solutions

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Malawi has lost a striking share of its forests over the past three decades. Woodlands that once covered well over a third of the country now cover less than a quarter, and the pressure on what remains is increasing. Behind those figures sit two practical questions: what is driving the loss, and what reverses it?

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