October 29, 2025

Hot Topics & Form 10-K: Climate

With respect to climate, the CAQ looked at what S&P 500 companies said in their 10-Ks about:

– Greenhouse gas emissions (scope 1, 2, and 3),

– Net zero, carbon neutral commitments, and other emissions reduction commitments, and

– Related reporting standards, frameworks, or requirements.

Almost all (494) S&P 500 companies mention climate change in their 10-K filings, and this number held steady year over year (after increasing since 2021 10-Ks). Not surprisingly, risk factor disclosure was most common (but slightly down year over year), while the number of companies mentioning climate in Item 1. Business and Item 7. MD&A was up.

In 2024, we observed a roughly 16% decrease in companies that disclosed a net zero or carbon neutral commitment compared with 2023. 74 companies (roughly 19% fewer than the prior year) indicated that they had a GHG emissions reduction goal.

[A] number of companies associated dollar amounts with their climate-related information. These disclosures varied and included capital expenses, research and development (R&D) costs, losses associated with severe weather events, investments, green bonds or sustainability-linked debt, and regulatory and compliance costs.

Financial statement disclosure also increased by 18% — usually related to significant accounting policies, commitments and contingencies or litigation, debt or borrowing arrangements and income taxes. There were even some CAMs (the critical audit matters section of the auditor’s report), for example: 

Regulatory Assets and Liabilities – Impact of Rate Regulation on the Consolidated Financial Statements: “These analyses are generally based on … considerations around the likelihood of impacts from events such as unusual weather conditions, extreme weather events and other natural disasters, and unplanned outages of facilities.”

Wildfire-Related Contingencies and Recoveries: “We identified wildfire-related contingencies and related-recoveries, specifically the WEMA, as well as the related disclosures as a critical audit matter because (1) of the significant judgments made by management to estimate losses, (2) the outcome of the wildfire-related contingencies materially affects the Company’s financial position, results of operations, and cash flows and (3) the significant judgments made by management in determining whether recoveries from WEMA are probable.”

Meredith Ervine 

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