In 2024, the Securities and Exchange Commission (SEC) issued its highly anticipated climate change disclosure rules. While the final rules were scaled back from the proposed rules with the addition of materiality qualifiers and other revisions to make certain rules less prescriptive, several petitions for review were filed in the U.S. Court of Appeals challenging their validity. In response to these legal challenges, the SEC placed an administrative stay on the rules’ implementation. Due to the stay and pending litigation, the compliance dates and phase-in periods, along with other aspects of the rules, remain uncertain. The SEC also issued final rules on Special Purpose Acquisition Companies (SPACs) that aim to align the investor protection and disclosure requirements associated with a SPAC or “de-SPAC transaction” with those applicable to a traditional initial public offering. Although SEC Chair Gary Gensler oversaw a robust rulemaking agenda in 2024, no other proposed or final rules in 2024 will have or have had a significant impact on SEC registrants’ financial reporting.
The SEC staff remained focused on post-implementation matters related to the SEC’s cybersecurity disclosure rules that were adopted in 2023 and issued several compliance and disclosure interpretations (C&DIs) and statements to assist registrants with their interpretation of the rules. The SEC staff also disseminated guidance about the interaction of its non-GAAP rules and regulations with the new segment reporting standard that will be effective for calendar year end registrants this year.
2024 SEC Reporting Reminders
- Cybersecurity Incident Disclosures
- Segment Disclosures
- Macroeconomic Conditions and Other Evolving Risks
- Clawback Checkboxes
- Select SEC Staff Comment Letter Topics
Commission and Staff Activities
- Final Rules
Our publication provides some key disclosure and reporting reminders for upcoming filings and summarizes the SEC’s rulemaking and other activities that affect financial reporting.