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The climate disclosure rules will become effective 60 days after publication in the Federal Register. But, in a change from the proposed rules, the phase-in periods were significantly extended in some cases — depending on filer status and the contents of the disclosure. The fact sheet includes this table showing the compliance dates for the new disclosure requirements by filer type:

Compliance Dates under the Final Rules(1)
Registrant Type	Disclosure and Financial Statement Effects Audit		GHG Emissions/Assurance			Electronic Tagging
	All Reg. S-K and S-X disclosures, other than as noted in this table	Item 1502(d)(2), Item 1502(e)(2), and Item 1504(c)(2)	Item 1505 (Scopes 1 and 2 GHG emissions)	Item 1506 – Limited Assurance	Item 1506 – Reasonable Assurance	Item 1508 – Inline XBRL tagging for subpart 1500(2)
LAFs	FYB 2025	FYB 2026	FYB 2026	FYB 2029	FYB 2033	FYB 2026
AFs (other than SRCs and EGCs)	FYB 2026	FYB 2027	FYB 2028	FYB 2031	N/A	FYB 2026
SRCs, EGCs, and NAFs	FYB 2027	FYB 2028	N/A	N/A	N/A	FYB 2027
	1  As used in this chart, “FYB” refers to any fiscal year beginning in the calendar year listed. 2  Financial statement disclosures under Article 14 will be required to be tagged in accordance with existing rules pertaining to the tagging of financial statements. See Rule 405(b)(1)(i) of Regulation S-T.

The first disclosures will be required of large accelerated filers covering fiscal years beginning in calendar 2025. Page 590 of the final rule release details this example:

[A]n LAF with a January 1 fiscal-year start and a December 31 fiscal year end date will not be required to comply with the climate disclosure rules (other than those pertaining to GHG emissions and those related to Item 1502(d)(2), Item 1502(e)(2), and Item 1504(c)(2), if applicable) until its Form 10-K for fiscal year ended December 31, 2025, due in March 2026.

If required to disclose its Scopes 1 and/or 2 emissions, such a filer will not be required to disclose those emissions until its Form 10-K for fiscal year ended December 31, 2026, due in March 2027, or in a registration statement that is required to include financial information for fiscal year 2026. Such emissions disclosures would not be subject to the requirement to obtain limited assurance until its Form 10-K for fiscal year ended December 31, 2029, due in March 2030, or in a registration statement that is required to include financial information for fiscal year 2029. The registrant would be required to obtain reasonable assurance over such emissions disclosure beginning with its Form 10-K for fiscal year ended December 31, 2033, due in March 2034, or in a registration statement that is required to include financial information for fiscal year 2033.

If required to make disclosures pursuant to Item 1502(d)(2), Item 1502(e)(2), or Item 1504(c)(2), such a filer will not be required to make such disclosures until its Form 10-K for fiscal year ended December 31, 2026, due in March 2027, or in a registration statement that is required to include financial information for fiscal year 2026.

Items 1502(d)(2), (e)(2) and 1504(c)(2) require disclosures of material expenditures incurred and material impacts on financial estimates and assumptions that directly result from activities to mitigate climate-related risks, from the company’s transition plan or from targets or goals or actions taken to meet any targets or goals. The SEC provided an additional phase-in period for these disclosures in recognition that registrants may need to develop systems and update disclosure controls to accommodate the tracking and reporting of these expenditures and impacts.

– Meredith Ervine