James B. Yard CPA, CIA, CISA
Organizations continue to see pressure on Environmental, Social and Governance (ESG) issues from customers, employees and investors. Increasingly, the public is seeking a stakeholder-centric approach to reporting, outside of just the financial results.
In response to this demand, the U.S Securities and Exchange Commission (SEC) will soon require public companies to report on the impact of climate change in their business operations under a proposed change to public company reporting focused on ESG data.
Formally announced on March 21, 2022, the SEC proposed this change to the required financial statement disclosures. The change would require public companies to report on their greenhouse gas emissions and the impact of climate change on business operations. The proposed rule outlines three scopes of data that public companies will be required to disclose.
If the proposed changes become a formal SEC regulation, registrants with the SEC will be required to provide climate-related information upon registration as a public company and in their regularly filed reports.
While publicly traded organizations will face additional required disclosures, private companies may also want to voluntarily report and receive third party assurance over their ESG information.
With our industry expertise and extensive knowledge of the risk advisory landscape, the Schneider Downs team can help your organization prepare for the proposed disclosure requirements and additional ESG-related risk by developing an ESG strategy that aligns with your overall corporate strategy.
ESG Framework Readiness and Implementation
Schneider Downs can help identify the appropriate frameworks based on the client, industry and user. Our team will map existing reporting and controls to the appropriate frameworks to identify opportunities and gaps in a state of maturity analysis and assist with the implementation of the required updates from the analysis. Our team can provide best practices on data validation and prepare your internal control process for ESG financial reporting and required metrics.
The Schneider Downs ESG team also provides ESG solutions for organizations responsible for non-financial data, data controls which both help KPI reporting and identify/test supporting ESG reporting controls and tax consulting for environmental/renewable energy tax credits.
The SEC released a proposed timeline for phase-in periods and accommodations for the proposed disclosures outlined below.
For explanatory purposes, the tables assume the proposed rules will be adopted during 2022 and that the filer has a December 31st fiscal year-end.
E.U. Environmental, Social, and Governance Proposals under CSRD
The European Union (E.U.) has proposed a revision to their own set of required disclosures for ESG reporting under the Corporate Sustainability Reporting Directive (CSRD). Under the CSRD, the E.U. is proposing mandatory disclosure requirements to drive ESG initiatives as organizations must report targets and progress towards achieving their goals.
The scope of organizations under this proposal extends well beyond those proposed by the SEC’s greenhouse gas requirements for public companies and is expected to impact roughly 50,000 organizations operating in E.U. member countries, including subsidiaries of U.S. companies.
For more information on the CSRD and potential impact please reference our article at www.schneiderdowns.com/our-thoughts-on/eu-esg-impact-on-us-companies.
Environmental, Social and Governance Resources
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About Schneider Downs Risk Advisory
Our team of experienced risk advisory professionals focus on collaborating with your organization to identify and effectively mitigate risks. Our goal is to understand not only the risks related to potential loss to the organization, but to drive solutions that add value to your organization and advise on opportunities to ensure minimal disruption to your business.
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