The Harvard Law School Forum on Corporate Governance https://corpgov.law.harvard.edu The leading online blog in the fields of corporate governance and financial regulation. Thu, 30 Apr 2026 11:32:16 +0000 en-US hourly 1 https://wordpress.org/?v=6.5.8 https://corpgov.law.harvard.edu/wp-content/uploads/2024/02/cropped-photography-4-e1706898544564-1-32x32.png Speech by Commissioner Roisman on Addressing Inevitable Costs of a New ESG Disclosure Regime – The Harvard Law School Forum on Corporate Governance https://corpgov.law.harvard.edu 32 32 Speech by Commissioner Roisman on Addressing Inevitable Costs of a New ESG Disclosure Regime https://corpgov.law.harvard.edu/2021/06/05/speech-by-commissioner-roisman-on-addressing-inevitable-costs-of-a-new-esg-disclosure-regime/?utm_source=rss&utm_medium=rss&utm_campaign=speech-by-commissioner-roisman-on-addressing-inevitable-costs-of-a-new-esg-disclosure-regime https://corpgov.law.harvard.edu/2021/06/05/speech-by-commissioner-roisman-on-addressing-inevitable-costs-of-a-new-esg-disclosure-regime/#comments Sat, 05 Jun 2021 14:29:07 +0000 https://corpgov.law.harvard.edu/?p=138470?d=20210605102907EDT Posted by Elad L. Roisman, U.S. Securities and Exchange Commission, on Saturday, June 5, 2021
Editor's Note:

Elad L. Roisman is a Commissioner at the U.S. Securities and Exchange Commission. The following post is based on his recent remarks at the Corporate Board Member ESG Board Forum. The views expressed in this post are those of Mr. Roisman and do not necessarily reflect those of the Securities and Exchange Commission or its staff.

Putting the Electric Cart before the Horse: [1] Addressing Inevitable Costs of a New ESG Disclosure Regime

I. Introduction

Thank you to Dan [Bigman] and the Corporate Board Member for inviting me to participate in today’s ESG Board Forum. Of course, the views I express here are my own and do not necessarily represent those of my fellow Commissioners.

As the topic of this event indicates, ESG is on everyone’s mind this year. There have been several calls for the SEC to require public issuers to include granular disclosure on ESG topics in their SEC filings. As you have probably heard me say before, [2] I have reservations about the SEC issuing prescriptive, line-item disclosure requirements in this space, particularly in the areas typically designated as environmental (“E”) or social (“S”) disclosure, although I know people’s categorization of ESG information can vary. [3] As someone recently put it to me, the reason that there is not standardized “E” data from companies yet is that standardization is very hard to do. Investors and fund managers have an insatiable desire for columns in spreadsheets, but some of the data that has been requested is inherently imprecise, relies on underlying assumptions that continually evolve, and can be reasonably calculated in different ways. And ultimately, unless this information can meaningfully inform an investment decision, it is at best not useful and at worst misleading.

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