Turner Commodities Law, PLLC
6353 Richmond Avenue, Suite 122
Houston, Texas 77057
(713) 899-5027
paul.turner@turnercommoditieslaw.com
1
Executive Summary
The SEC’s 2024 Climate Disclosure Rule is in an unusual posture: still formally in effect, not being
enforced, not being defended in court, and not being repealed. After the SEC withdrew its defense of
the rule in March 2025, the Eighth Circuit held the litigation in abeyance indefinitely as of September
2025. The result is regulatory suspension without legal death.
For trading organizations, the risk is asymmetric. You do not need to comply today — but the rule
remains a fully promulgated regulation the SEC could reactivate without starting over. Meanwhile,
banks, insurers, and global corporates continue to treat climate-risk transparency as standard diligence,
even as some U.S. companies reduce the visibility of ESG programs in response to shifting political
winds.
This is regulatory limbo with real-world trading implications.
Background
The rule grew out of a multi-year SEC effort to standardize climate-related disclosure after an
unprecedented volume of public comment. The SEC grounded the rule in its classic mandate to
require disclosures “necessary or appropriate” for investor protection — emphasizing financial
materiality rather than environmental regulation.
Core Components of the Rule
As adopted in 2024, the Rule required public companies to disclose:
• material climate-related risks that could affect financial condition or operations
• board and management oversight of climate-related issues
• risk-management processes for identifying and integrating climate risk into enterprise risk
management
• quantified financial impacts of severe weather events or transition activities in audited financial
statements
• Scope 1 and Scope 2 greenhouse gas emissions for certain filers, if material notably, the final rule
excluded the controversial Scope 3 requirement that had been in the proposal). Enhancement and
Standardization of Climate-Related Disclosures for Investors, Rel. No. 33-11275 (Mar. 6, 2024).
Although framed as a disclosure regime, the rule forced registrants to build data pipelines, internal
controls, and governance structures that required meaningful investment.
6353 Richmond Avenue, Suite 122
Houston, Texas 77057
(713) 899-5027
paul.turner@turnercommoditieslaw.com
1
Executive Summary
The SEC’s 2024 Climate Disclosure Rule is in an unusual posture: still formally in effect, not being
enforced, not being defended in court, and not being repealed. After the SEC withdrew its defense of
the rule in March 2025, the Eighth Circuit held the litigation in abeyance indefinitely as of September
2025. The result is regulatory suspension without legal death.
For trading organizations, the risk is asymmetric. You do not need to comply today — but the rule
remains a fully promulgated regulation the SEC could reactivate without starting over. Meanwhile,
banks, insurers, and global corporates continue to treat climate-risk transparency as standard diligence,
even as some U.S. companies reduce the visibility of ESG programs in response to shifting political
winds.
This is regulatory limbo with real-world trading implications.
Background
The rule grew out of a multi-year SEC effort to standardize climate-related disclosure after an
unprecedented volume of public comment. The SEC grounded the rule in its classic mandate to
require disclosures “necessary or appropriate” for investor protection — emphasizing financial
materiality rather than environmental regulation.
Core Components of the Rule
As adopted in 2024, the Rule required public companies to disclose:
• material climate-related risks that could affect financial condition or operations
• board and management oversight of climate-related issues
• risk-management processes for identifying and integrating climate risk into enterprise risk
management
• quantified financial impacts of severe weather events or transition activities in audited financial
statements
• Scope 1 and Scope 2 greenhouse gas emissions for certain filers, if material notably, the final rule
excluded the controversial Scope 3 requirement that had been in the proposal). Enhancement and
Standardization of Climate-Related Disclosures for Investors, Rel. No. 33-11275 (Mar. 6, 2024).
Although framed as a disclosure regime, the rule forced registrants to build data pipelines, internal
controls, and governance structures that required meaningful investment.
