ITI Submits Comments to SEC Proposed Rules on Climate-Related Disclosures for Investors
WASHINGTON – Today, global tech trade association ITI submitted comments to the Securities and Exchange Commission’s (SEC) proposed rules on The Enhancement and Standardization of Climate-Related Disclosures for Investors. In its submission, ITI highlights its support of the SEC’s intent to provide investors with appropriate information on material aspects of issues like climate change. ITI has long promoted the importance of digitalization in reducing the carbon footprint of all economic sectors and its member companies have taken significant steps to improve sustainability and reduce their greenhouse gas emissions. To help the SEC meet the proposed rule’s stated goals, ITI offers recommendations to ensure companies can implement the final rule without harm to innovation.
“ITI represents the leading global innovators of information and communications technology, an industry with a demonstrated commitment to corporate sustainability initiatives and transparency,” ITI wrote in the comments. “The industry is reported to be one of the few sectors that is ‘on track’ to decarbonize, and was also the first to develop sectoral targets approved by the Science Based Targets Initiative. ITI and its members fully support the SEC’s intent to provide investors with ‘consistent, comparable, and decision-useful information for making their investment decisions’ while also ensuring that there are ‘consistent and clear reporting obligations’ for issuers.”
Tech-enabled efficiency and decarbonization solutions provide carbon reduction opportunities to other sectors of the economy. Further, investment in innovative technologies and in jobs creation needed to mitigate and address climate change will not only help address and minimize its impacts but will also support global economic competitiveness and promote investments that help avoid irreversible damage to our economies, societies and planet.
In its comments, ITI underscores that critical changes to the SEC’s proposed provisions are needed to ensure the final requirements are reasonably workable for registrants and ultimately further the SEC’s stated goals. To that end, ITI offers the following recommendations to the SEC’s proposed rule on climate-related disclosures:
- Provide further accommodations, guidance, and tools to support any requirements to disclose Scope 3 GHG emissions.
- Establish and strength proposed safe harbor to cover all greenhouse gas emissions disclosures.
- Narrow and focus definitions of “climate-related risks,” “transition risks,” and “climate-related opportunities.”
- Do not require registrants to disclose data or information from historical periods.
- Establish a specialized form and timeline for submissions of climate-related disclosures and allow registrants to keep such disclosures separate from other periodic reports that must be filed with the SEC.
Read ITI’s full submission to the SEC here.
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