This page provides background information on corporate engagement on the US Securities and Exchange Commission (SEC) climate disclosure rule. If you would like to reference any of this information, please use the evidence, entity profile, or report links shared below, which link back to our LobbyMap platform.
This background briefing provides an overview of corporate engagement on the SEC climate diclosure rule. The analysis covers submissions tracked on the rule from large companies and industry associations covered by InfluenceMap's LobbyMap database, but it does not cover the entirety of submissions made. The LobbyMap database covers 750 of the world's largest companies and 300 of the worlds largest industry associations. This engagement was captured between June 2022 and February 2025.
On March 6, 2024, the US Securities and Exchange Commission (SEC) adopted final rules “to enhance and standardize climate-related disclosures.” The final rules were reached following consultation over a two-year period and, “based upon public feedback,” the final rule removed several provisions from the proposed draft, including the proposed Scope 3 Greenhouse Gas (GHG) emission disclosure requirement. Throughout the two-year consultation, a number of industry groups displayed significant opposition to the rule—including the Business Roundtable and the US Chamber of Commerce (the Chamber)—which continued after the release of the final rule. Currently, these industry groups are engaged in a lawsuit against the rule, which is being heard by the US Court of Appeals for the Eight Circuit.
On February 11, 2025, SEC Acting Chair Mark Uyeda requested that SEC staff ask the Eighth Circuit to pause arguments on the case pending an SEC decision on whether to continue to defend the rule. In his statement, Uyeda asserted that:
"During the comment period, many submissions likewise urged that the Rule not be adopted. Among the reasons were that the Rule would require a large volume of financially immaterial information, financially material climate-related risks were already subject to disclosure under existing rules, and the proposed rules overstepped the SEC's regulatory authority."
InfluenceMap has tracked engagement on this rulemaking over several years (November 2021, April 2024, July 2024). From Uyeda’s announcement, it appears that a small number of influential industry groups may be close to achieving their long-fought goal of eliminating any requirement for US companies to report on climate risks or greenhouse gas emissions.
The pie chart below shows InfluenceMap’s assessment of direct communications to the SEC regarding the proposed rule from large companies and industry associations tracked by the LobbyMap database. Positions range from “opposing” to “strongly supporting.” Where companies and industry associations have submitted multiple letters or communications, these are assessed individually.
InfluenceMap’s assessment finds that opposition came from a small group of powerful voices: approximately 16% of communications tracked fully opposed the rule. Of this opposition, the majority (83%) came from industry associations, such as the American Legislative Exchange Council , the American Petroleum Institute, the American Chemistry Council, the National Association of Manufacturers, and the US Chamber, with 25% coming from the Chamber alone.
* rounded figures
Many commenters took a nuanced position on the proposed rule, as evident in the below pie chart: over 90% of the “not supporting” positions that InfluenceMap analyzed included objections to proposed Scope 3 emissions disclosures, which were removed from the final rule. Other than NAM, which stated that it “appreciates that the SEC listened to manufacturers across the country,” the rule’s opponents largely ignored the concessions made in the final version of the rule, and, in his recent statement, Acting Chair Uyeda neglected to mention them.
In his February statement, the SEC Acting Chair cited four letters, all of which came from industry groups: the Chamber of Commerce, NAM, the American Bar Association, and the National Association of Convenience Stores. Given that the consultation received record levels of feedback with over 24,000 responses submitted, this represents less than 0.02% of the comments received and is not representative of the position of the majority of respondents, with over 90% of the non-unique submissions (18,103 responses) supporting the rule. The statement also failed to cite supportive arguments from industry groups, including the Council of Institutional Investors (CII), which has at least 19 member companies that also retain membership to the Chamber, and the American Clean Power Association, which has at least 22 members that also are members of the Chamber.
Previous InfluenceMap research demonstrates that, in their opposition to the climate disclosure rules, cross-sector industry groups including the Business Roundtable and the Chamber are misaligned with members that are supportive of the rules. These industry groups instead appear to take the “lowest common denominator” position of fossil fuel members and other obstructive companies, including ExxonMobil and ConocoPhillips.
The Acting Chair's reasons for pausing arguments over the rule–that “many” commenters said that the disclosures required were immaterial, that existing material risks are already captured under existing law, and that the Commission lacks the authority to promulgate the rule—seem to mirror the industry association responses cited. In its consultation response, the Chamber, which in its own words has been “at the forefront of fighting” the rules, claimed that “the Proposing Release is frequently dismissive of the significant climate and environmental disclosures that public companies already make.” It also argued that “the Proposed Rules exceed the Commission’s statutory authority.” NAM stated that it was “going to throw the full weight of the industry behind [this] effort” and argued that the SEC did not have the statutory authority to introduce the proposed rule—however, this was emphasized within the context of Scope 3 emissions disclosure.
Other industry groups promoted the argument around the Commission’s lack of statutory authority, including the Texas Alliance of Energy Producers, American Fuel & Petrochemical Manufacturers, and the American Petroleum Institute, among others. Now, this idea appears to have been taken up by the same agency that once issued the rule.