Who’s impacted?
All SEC registrants, except asset-backed issuers and certain Canadian companies who file under the Multijurisdictional Disclosure System (MJDS).
What’s the latest?
On May 29, 2026, the SEC formally proposed to rescind the Rule. The proposal is subject to a 60-day public comment period closing on August 3, 2026 with a final vote by the SEC expected to follow. For more information see press release here.
What do Canadian CPAs need to know?
While the SEC's May 29, 2026 proposal seeks to completely rescind the Rule, Canadian CPAs should note how the Rule was structured and whom it would have affected.
The scope of the Rule would have applied to nearly all SEC registrants.
Canadian companies that are registrants with the SEC that file using the MJDS and file their Exchange Act registration statements and annual reports on Form 40-F would not have been subject to reporting under the Rule.
However, Canadian companies that are either U.S. domestic registrants that file their Exchange Act registration statements and Annual Reports on Form 10-K, or Foreign Private Issuers (FPI) that file their Exchange Act registration statements and Annual reports on Form 20-F, would have been subject to the Rule.
Additionally, a Canadian subsidiary of a company that is in-scope of the Rule (e.g. a Canadian subsidiary of a U.S. domestic filer) could have been required to provide climate-related information required by the Rule to their parent company.
Although the SEC Rule is currently stayed and unenforced, Canadian companies may still be subject to state-level climate laws, such as those in California. For more information see, At a Glance - Sustainability Reporting Standards & Regulations.
Where can I learn more?
For more information, please refer to our SEC Climate Rule Summary and our FAQs
You can also refer to:
