On March 21, 2022, the Securities and Exchange Commission proposed climate-related disclosure requirements (the “Proposed Rules”) that would require U.S. public companies and foreign private issuers to dramatically expand the breadth, specificity and rigor of climate-related disclosures in their SEC periodic reports and registration statements. The Proposed Rules, set out in a 510-page proposing release, mark a significant departure from the SEC’s traditional principles- and materiality-based reporting framework and move towards a prescriptive climate-related disclosure regime that mandates reporting of detailed information regardless of its materiality. The Proposed Rules, if adopted, will meaningfully increase the cost and complexity of public reporting. To enable compliance, companies will need to expend significant advance effort to enhance, among other things, data collection procedures (including from third parties in their value chain), and internal processes and controls, which will require substantial internal and external resources (including audit oversight of novel financial statement requirements).