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With apologies to Samuel Beckett, the SEC’s latest decision to kick its proposed climate change rules down the road has our editorial team starting to feel a bit like Vladimir & Estragon in Waiting for Godot. My colleagues and I may be able to languish in our existential crisis, but we don’t think companies can afford to wait for the SEC to act before preparing for heightened climate disclosure obligations.

That’s because even if the SEC does nothing, many US companies are soon going to find themselves confronting the rather daunting climate disclosure obligations imposed by the EU’s CSRD disclosure requirements, California’s recent climate disclosure legislation, and increasing stakeholder demands. So, what should companies do while they’re waiting for the SEC’s final rules? Matt Kelly offered up some advice over on his Radical Compliance blog:

You already know climate change disclosures are coming for your enterprise eventually, whether that’s from Europe, California, activist investors, or consumer pressures. Many large companies either already provide some climate change disclosure, or they’re preparing to do so in the immediate future. None of that is likely to change just because the SEC is stalling its final rule for another few months.

Indeed, just this week the Center for Audit Quality (a lobbying voice for large accounting firms) released its 2023 Audit Partner Pulse Survey, where it surveyed audit partners about the issues they see at the forefront of their client companies’ minds. Forty-five percent of respondents said they expect their client companies to disclose more information about environmental or climate issues in 2024, more than any other issue on the 2024 radar.

In other words, the SEC delay might give you more time to proceed down the path to greater disclosure of greenhouse gasses and other climate factors — but you’ll still need to go down that path. The same ESG disclosure and audit issues that have flummoxed companies already are still there.

Do you fully understand the climate change proposal in the first place, such as which gasses must be tracked and how other disclosure protocols fit into the SEC’s thinking?

Do you have an ESG reporting structure, and is that structure wise given all the other reporting and assurance duties you already have?

Have you considered any frameworks to guide your sustainability reporting, such as the framework COSO released earlier this year?

Matt closes by advising companies to “use your time wisely” – or as Vladimir put it in Waiting for Godot, “…Let us not waste our time in idle discourse! Let us do something, while we have the chance…”

– John Jenkins