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. Wed, 03 Jun 2026 20:58:09 +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 ESG Disclosure Trends in SEC Filings – The Harvard Law School Forum on Corporate Governance https://corpgov.law.harvard.edu 32 32 ESG Disclosure Trends in SEC Filings https://corpgov.law.harvard.edu/2022/07/16/esg-disclosure-trends-in-sec-filings/?utm_source=rss&utm_medium=rss&utm_campaign=esg-disclosure-trends-in-sec-filings https://corpgov.law.harvard.edu/2022/07/16/esg-disclosure-trends-in-sec-filings/#comments Sun, 17 Jul 2022 03:14:37 +0000 https://corpgov.law.harvard.edu/?p=147596?d=20220716231437EDT Posted by Maia Gez, Era Anagnosti, and Taylor Pullins, White & Case LLP, on Sunday, July 17, 2022
Editor's Note:

Maia Gez, Era Anagnosti, and Taylor Pullins are partners at White & Case LLP. This post is based on a White & Case memorandum by Ms. Gez, Ms. Anagnosti, Mr. Pullins, Colin Diamond, Scott Levi, and Melinda Anderson.

The regulatory landscape for ESG disclosure by U.S. public companies faces potentially dramatic changes, with the Securities and Exchange Commission (“SEC”) proposing rules that would mandate comprehensive climate change disclosures and integrate key aspects of sustainability reporting with annual reports. [1] Against this backdrop, White & Case surveyed the SEC filings of 50 companies in the Fortune 100 to assess the latest trends in ESG disclosure.

Survey of ESG Disclosure—2020 to 2022

For its fourth annual survey of ESG disclosure in SEC filings, [2] the White & Case Public Company Advisory Group reviewed the annual meeting proxy statements and annual reports of 50 companies in the Fortune 100. [3] In these 100 SEC filings, we focused on 12 categories [4] of ESG disclosure in annual reports and proxy statements filed with the SEC in 2020, 2021 and 2022. The key trends and takeaways from our survey are discussed below.

Climate-Related Disclosure Takes the Spotlight in 2022

In the fall of 2021, ahead of Form 10-K filings, the SEC issued a sample comment letter on climate disclosure [5] and also issued bespoke comment letters to a number of companies questioning their materiality assessments with respect to climate disclosure. Climate-related disclosure significantly increased in both Form 10-K and proxy statement filings of the surveyed companies, with many companies including such disclosure for the first time in 2022. Our survey focused on the ways climate disclosure changed year-over-year among the surveyed companies.

The Seven ESG Topics on the Rise in 2022

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