SEC climate-related disclosure rules (stalled and proposed for rescission)

The SEC published the final climate-related disclosure rules in the Federal Register on 2024-03-28 (89 FR 21668), originally effective 2024-05-28. On 2024-04-12 it announced (89 FR 25804) that the effective date is delayed indefinitely pending completion of the consolidated Eighth Circuit review, with a further Federal Register notification to follow. On 2026-06-03 the SEC published a proposed rule (91 FR 33296) to rescind those climate-related disclosure rules, with comments due 2026-08-03. No final rescission rule was observed as of 2026-09-12. Companies listed or listing in the United States should therefore not prepare disclosure as though the rules were in force, but equally should not infer that no other climate disclosure obligations apply.

Applies when

Chinese AI companies planning a U.S. IPO or already listed there, and the teams preparing their ESG reporting.

Evidence to retain

• · Status tracking register recording Federal Register citations and the date checked
• · Statement of the status assumptions underlying the disclosure preparation plan
• · Confirmation records with auditors and counsel
• · Comparison table of climate disclosure duties in other jurisdictions, to avoid generalizing from the U.S. status

Estimated first-time effort: 1–4 person-days (estimate, not a commitment)

Even while the federal rule is stalled, climate data capability retains commercial value: supply chain questionnaires from U.S. enterprise customers, investor diligence and mandatory regimes in other jurisdictions all draw on the same underlying data. Retain the emissions accounting boundary, activity data collection processes and data quality controls rather than suspending the build-out as the rule status changes. This item is practical guidance and does not assert a current SEC mandate.

Applies when

Chinese AI companies planning a U.S. listing or serving U.S. enterprise customers.

Evidence to retain

• · Emissions accounting boundary and methodology documentation
• · Activity data collection workflow and data quality control records
• · History of responses to customer supply chain questionnaires
• · Internal allocation of responsibility for climate data governance

Estimated first-time effort: 5–20 person-days (estimate, not a commitment)