How Should Companies Approach Internal Controls Over Sustainability Reporting?

With the SEC’s new climate disclosure rules adopted in March 2024, companies are preparing for implementation—even as the rules face legal challenges and have been temporarily stayed.

Key Context

The SEC’s Enhancement and Standardization of Climate-Related Disclosures for Investors (Release No. 33-11275) represents a landmark step in climate-related reporting. While litigation has delayed enforcement, many companies are moving ahead with preparations, recognizing that investor demand and global regulatory trends will continue to drive sustainability disclosure. At the same time, concerns have been raised about the current quality and reliability of sustainability information. To address these challenges, companies and advisors are turning to the COSO framework Achieving Effective Internal Control Over Sustainability Reporting (ICSR) as a guide for building systems that strengthen the accuracy, accountability, and transparency of ESG and climate disclosures.

What You’ll Learn

This Issue Brief explains how the SEC’s climate disclosure rules intersect with the growing focus on internal controls over sustainability reporting. You’ll learn why companies are adopting COSO’s ICSR framework to prepare for compliance, how these controls can improve confidence in reported information, and what this means for building trust with investors and stakeholders. The brief highlights the practical steps companies can take now to operationalize reporting processes, align with global standards, and ensure resilience in the face of evolving regulatory requirements.

Issue Brief

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