On March 31, 2021, Acting SEC Chair Allison Herren Lee directed the Division of Corporation Finance to begin focusing on climate-related disclosures. This is the first action the SEC has taken to address climate-related disclosure since the Commission’s 2010 Interpretive Guidance. The action comes after the Commission issued final rules on the Modernization of Regulation S-K Items 101, 103, and 105, which many believe was a missed opportunity to update disclosure rules around climate-related issues.

In this article, Audit Analytics examines the SEC's decision as well as the drop in the number of comment letters referencing climate change over the years.