SEC climate disclosure rule: where it stands in 2026, and what it means for you

The SEC climate disclosure rule is, as of July 2026, on its way out. The Commission voted on May 29, 2026 to propose rescinding the rules in their entirety, published that proposal on June 3, 2026, and set a comment deadline of August 3, 2026, with a final rescission vote expected later in the year. The rules it is unwinding had never actually taken effect: the SEC adopted them in March 2024, then stayed them within weeks as litigation piled up. So the honest answer to "do I have to comply with the SEC climate rule?" is no, you never did, and the agency is now formally removing it from the books.

That is the easy part. The harder and more useful question is what the rescission does and does not change for a US company, because a lot of teams read the headline and concluded that emissions reporting had gone away. It has not. The federal rule was only ever one source of pressure, and it was the one least likely to survive. The sources that remain are state law, your own customers, and your investors, and none of them took the summer off.

What the SEC actually did, in plain terms

In March 2024 the SEC adopted rules that would have required public companies to disclose climate-related risks, governance and, for larger filers, Scope 1 and Scope 2 greenhouse gas emissions in their filings. The rules drew immediate legal challenges, and the Commission stayed them in April 2024 rather than defend them into effect. They sat stayed for two years. Then, in 2026, the Commission changed direction entirely: rather than litigate the rules into force, it proposed to rescind them, arguing they exceeded the agency's statutory authority and did not fit a materiality-based disclosure regime.

The mechanics from here are a normal rulemaking. Updated August 2026: the comment window closed on August 3, 2026, so the proposal is now with the Commission, which will vote on a final rescission after reviewing what came in. Barring a surprise, the federal climate disclosure rule ends without ever having required a single filing.

Which leaves a gap worth naming. With no federal rule, the reporting obligations US companies actually face come from three other directions: California, where SB 253 has a live November 10, 2026 deadline; customers and investors, usually through the CDP questionnaire; and international standards reaching US entities through subsidiaries and parents, covered in our note on IFRS carbon accounting. The SEC rescission removes one deadline from the calendar. It does not remove the others.

There is also a fourth direction that gets overlooked precisely because it is old news. EPA's Greenhouse Gas Reporting Program is still binding federal law for the 8,000-odd facilities it reaches, and its reporting year 2025 deadline was moved to October 30, 2026. EPA has proposed to gut it and has not finalized that proposal, which has left a lot of covered facilities assuming an obligation lapsed when it did not. The current status is set out on EPA GHG reporting, and how it differs from the California obligation is in EPA GHG reporting vs SB 253.

Does this mean US companies can stop measuring emissions?

No. This is the mistake that will cost some teams a scramble later. The SEC rule going away removes one federal obligation that had never bitten. It does nothing to California law, nothing to your customers' supplier questionnaires, and nothing to the European rules that reach US firms through the value chain. If you were in scope for any of those before May 2026, you still are.

The demand for a credible emissions number simply moved from one federal rule to a more fragmented set of sources. That is arguably harder to manage, not easier, because a patchwork of state and contractual obligations is exactly the kind of thing that is easy to lose track of. Companies that map their obligations across every jurisdiction and contract in one place tend to catch the requirements that a single-rule mindset misses.

What is the binding US requirement now?

California. The state's two climate laws are the closest thing the US has to a mandatory disclosure regime in 2026, and they are in force while the SEC rule dissolves.

Both test total annual revenue, not California revenue, on the lesser of your previous two fiscal years. A company with $1.3 billion in global revenue and a sales office in California is in scope for SB 253 on its global number. The threshold work is covered in SB 253 vs SB 261, and the tooling in SB 253 reporting software.

And the pressure that has no deadline: your customers

Even a company well under $1 billion, with no California nexus, is not off the hook if it sells to larger companies. Firms reporting under Europe's CSRD, or under their own net-zero commitments, need Scope 3 reporting numbers, and your emissions are their category 1. Those supplier questionnaires arrive on the customer's schedule, not a regulator's, and "we don't have a number" is increasingly a commercial problem in a procurement review. This channel of demand did not exist because of the SEC rule and does not disappear with it.

So what should you actually do?

Build the inventory, and stop waiting for a single rule to tell you the exact format. The work underneath every one of these obligations is identical: a classified greenhouse gas inventory with an evidence trail from each figure back to the record that produced it. Once you have that, an SB 253 submission, a CSRD data pack and a customer questionnaire are all projections of the same number rather than three separate projects.

1. Confirm which obligations touch you. Revenue and California nexus for SB 253 and SB 261; your customer base for questionnaire risk; any European footprint for CSRD and CBAM reporting.
2. Pull the data you already have. Scope 1 and 2 live in fuel, refrigerant and utility records. Scope 3 starts from your accounts payable spend, and ESG data collection software is what turns those scattered systems into one feed.
3. Classify and keep the evidence. Every line to a scope and category, with the reason and the source document attached, so the number survives a review.

That classified ledger is exactly what our carbon accounting software builds from the AP and utility data you already own, and the wider US picture, including what the SEC rescission changes, sits on climate disclosure software. You can run the classifier on your own lines in the demo before you talk to anyone.

This describes the SEC's proposed rescission of its climate-related disclosure rules and the status of California SB 253 and SB 261 as published in July 2026. The SEC rulemaking and the SB 261 litigation are both ongoing, so dates and outcomes can change; confirm current status with the SEC and CARB. Nothing here is legal advice.