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Keeping you in-the-know on environmental, social and governance developments

Ceres, the climate management and accounting platform Persefoni, and environmental consultancy ERM (through their SustainAbility Institute) recently conducted a study to

… reveal[] what U.S. private sector organizations currently spend measuring and managing climate change data and disclosure.

Ceres and Persefoni commissioned the survey to help inform mandatory and voluntary climate disclosure guidelines and methods being developed by regulators, standard setters, and individual firms. Specifically, the survey findings are intended to inform discussions related to the US Securities and Exchange Commission’s (SEC) recent proposed rule…

At the moment, only the fact sheet is available – a detailed white paper should be released soon. The overall finding:

Compared to the SEC’s estimate of $530,000 per corporate issuer, the ERM survey finds that corporate issuers currently spend $533,000 per year on climate-related disclosure activities that would be required by the SEC’s proposed rule. This suggests the SEC’s estimated costs closely align with corporate issuers’ current average spend and reflect a realistic assessment of market practice.

The study also considered additional costs not considered by the SEC in their proposal (and therefore not included in the above estimate), such as those associated with:

  • proxy responses to climate-related proposals (in-house, outside counsel, and proxy solicitor analysis of shareholder voting for ballot items)
  • voluntarily developing low-carbon transition plans, stakeholder engagement, government relations, and the preparation of related disclosures;
  • institutional investor collection, analysis, and reporting climate data to inform their investment decisions; and
  • internal climate risk management controls.

Tim Mohin, Persefoni’s Executive Vice President and Chief Sustainability Officer, will be a panelist in our 1st Annual Practical ESG Conference on October 11. Get the best price by registering today – online by credit card or by emailing You can purchase access to this conference on a standalone basis – or bundle & save by also registering for our Proxy Disclosure & 19th Annual Executive Compensation Conferences the same week – which will specifically explore proxy issues related to climate matters.

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The Editor

Lawrence Heim has been practicing in the field of ESG management for almost 40 years. He began his career as a legal assistant in the Environmental Practice of Vinson & Elkins working for a partner who is nationally recognized and an adjunct professor of environmental law at the University of Texas Law School. He moved into technical environmental consulting with ENSR Consulting & Engineering at the height of environmental regulatory development, working across a range of disciplines. He was one… View Profile