Comprehensive Analysis of the SECs Landmark Climate Disclosure Rule March 15 2024
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Questions and Answers

When was the IFRS S1 and IFRS S2 regulation set to become effective?

  • January 1, 2025
  • January 1, 2023
  • January 1, 2024 (correct)
  • January 1, 2022
  • Which organization was asked to assume the role of monitoring the progress of corporate climate-related disclosures after the TCFD was disbanded?

  • AICPA
  • IFRS Foundation (correct)
  • EITF
  • PCAOB
  • For which affected companies is SB-253 applicable?

  • U.S.-based public companies only
  • Public companies registered with the SEC
  • Public and private companies in the E.U. (correct)
  • Non-U.S.-based companies
  • When is the first mandatory reporting under the Final Rule expected to start?

    <p>2025</p> Signup and view all the answers

    Which piece of legislation sets the starting date for disclosure requirements in the U.S.?

    <p>California Climate Disclosure Legislation (SB-253 and SB-261)</p> Signup and view all the answers

    Which entity might be required to comply with the CSR/ESRS disclosure regulations starting in 2024?

    <p>Public and private companies in the E.U.</p> Signup and view all the answers

    When should registrants provide transition disclosures about the impact of recently issued accounting standards on financial statements?

    <p>Upon the adoption of the accounting standards</p> Signup and view all the answers

    When will the financial statement disclosures regarding recently issued accounting standards be subject to existing financial statement audit requirements?

    <p>Before the compliance date</p> Signup and view all the answers

    Which regulation was amended to require specific disclosures enumerated in Regulation S-X, Article 14?

    <p>Regulation S-X, Article 8</p> Signup and view all the answers

    Why should registrants begin establishing accounting policies and internal controls in advance of their compliance date?

    <p>To address financial statement disclosures about recently issued accounting standards</p> Signup and view all the answers

    Which section of the regulations governs the financial statements required for Smaller Reporting Companies (SRCs)?

    <p>Article 8</p> Signup and view all the answers

    In what section of the SAB Topic 11.M are registrants required to provide transition disclosures?

    <p>(SAB 74)5</p> Signup and view all the answers

    What is the main requirement of the IFRS Sustainability Disclosure Standards?

    <p>To include sustainability-related financial disclosures in financial reports</p> Signup and view all the answers

    How did the final rule address concerns regarding the adoption timeline for large accelerated filers?

    <p>Extended the adoption timeline</p> Signup and view all the answers

    What does the final rule establish regarding the materiality threshold for Scope 1 and Scope 2 GHG emission metrics?

    <p>Registrants can omit this information if it's not material</p> Signup and view all the answers

    Under the final rule, how many years do large accelerated filers have to obtain limited assurance over GHG emissions?

    <p>Six years</p> Signup and view all the answers

    What was the adoption timeline for large accelerated filers under the proposed rule?

    <p>One year</p> Signup and view all the answers

    What was the main concern addressed by establishing a materiality threshold for Scope 1 and Scope 2 GHG emission metrics?

    <p>Allowing registrants to omit immaterial GHG emission disclosures</p> Signup and view all the answers

    Study Notes

    Disclosure Regulations

    • The TCFD (Task Force on Climate-related Financial Disclosures) was disbanded on October 12, 2023, and the Financial Stability Board asked the IFRS Foundation to monitor corporate climate-related disclosures.

    Comparison of Disclosure Regulations

    • The CSRD/ESRS (European Union's Corporate Sustainability Reporting Directive/European Sustainability Reporting Standards) has a first mandatory reporting deadline starting with 2024, depending on entity structure and size.
    • The IFRS Sustainability Disclosure Standards require sustainability-related financial disclosures in general-purpose financial reports.

    California Climate Disclosure Legislation

    • SB-253 and SB-261 require climate-related disclosures, with a first mandatory reporting deadline in 2025 (due in 2026) for affected companies.

    Final Rule

    • The final rule applies to public companies registered with the SEC and has a transition timeline, with large accelerated filers having nearly two years to provide most disclosures.
    • The final rule establishes a materiality threshold for Scope 1 and Scope 2 GHG emission metrics, allowing registrants to omit disclosures if not material.
    • Registrants should establish accounting policies and internal controls in advance of their compliance date.

    Audit Considerations and Internal Controls

    • Financial statement disclosures will be subject to existing financial statement audit requirements and management's internal control over financial reporting (ICFR).

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    Deloitte, March 15 2024

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