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. Sun, 05 Apr 2026 11:30:09 +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 Climate Disclosure and the Transformation of Gatekeeping – The Harvard Law School Forum on Corporate Governance https://corpgov.law.harvard.edu 32 32 Climate Disclosure and the Transformation of Gatekeeping https://corpgov.law.harvard.edu/2026/02/10/climate-disclosure-and-the-transformation-of-gatekeeping/?utm_source=rss&utm_medium=rss&utm_campaign=climate-disclosure-and-the-transformation-of-gatekeeping https://corpgov.law.harvard.edu/2026/02/10/climate-disclosure-and-the-transformation-of-gatekeeping/#respond Tue, 10 Feb 2026 12:31:17 +0000 https://corpgov.law.harvard.edu/?p=179183?d=20260209164441EST Posted by Andrew F. Tuch (Washington University in St. Louis), on Tuesday, February 10, 2026
Editor's Note:

Andrew F. Tuch is Professor of Law at Washington University in St. Louis. This post is based on his recent paper.

How might enhanced climate disclosures disrupt the verification practices of gatekeepers in capital markets transactions? Relatedly, should GHG emissions metrics be certified by experts? In a recent essay, I explore these questions, using the SEC’s now-stayed 2024 Climate Rule as a guide.

Enhanced climate disclosures are inevitable, and their credibility will depend on robust verification mechanisms. Moreover, the Climate Rule itself still matters, whatever its eventual fate. Shaped by years of input and detailed analysis, it offers lessons to guide future regulatory design. And even if the Rule, or a revised version, never takes effect, disclosure regimes in other jurisdictions are likely to require similar disclosures and have a comparable impact on issuers and gatekeepers. (more…)

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