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pdfSUPPORTING STATEMENT FOR PROPOSED RULES RELATING TO THE
ENHANCEMENT AND STANDARDIZATION OF CLIMATE-RELATED
DISCLOSURES FOR INVESTORS
This supporting statement is part of a submission under the Paperwork Reduction Act of
1995 (“PRA”).1
A.
JUSTIFICATION
1. CIRCUMSTANCES MAKING THE COLLECTION OF INFORMATION
NECESSARY
On March 21, 2022, the Securities and Exchange Commission (“Commission”) proposed
rule amendments to enhance and standardize climate-related disclosures for investors.2 The
proposed amendments would create a new section (Subpart 1500) of Regulation S-K that would
require a domestic or foreign registrant to include certain climate-related information in its
registration statements and periodic reports, such as its annual reports on Form 10-K or Form 20F, including information about a registrant’s:
• climate-related risks that are reasonably likely to have a material impact on the registrant,
including on its business or consolidated financial statements, which may manifest over
the short, medium, and long term;
• governance of climate-related risks and relevant risk management processes;
• greenhouse gas (“GHG”) emissions, which, for accelerated and large accelerated filers
and with respect to certain emissions, would be subject to assurance; and
• climate-related targets and goals, and transition plan, if any.
The proposed amendments would also create a new section (Article 14) of Regulation S-X that
would require the disclosure of certain climate-related financial statement metrics and related
disclosures in a note to the registrant’s audited financial statements.
The proposed amendments contain “collection of information” requirements within the
meaning of the PRA. The titles for the collection of information are:
•
•
•
•
•
•
•
•
•
Form S-1 (OMB Control No. 3235-0065);
Form F-1 (OMB Control No. 3235-0258);
Form S-4 (OMB Control No. 3235-0324);
Form F-4 (OMB Control No. 3235-0325);
Form S-11 (OMB Control No. 3235-0067);
Form 10 (OMB Control No. 3235-0064);
Form 10-K (OMB Control No. 3235-0063);
Form 10-Q (OMB Control No. 3235-0070);
Form 20-F (OMB Control No. 3235-0288); and
1
44 U.S.C. §3501, et seq.
2
See Release No. 33-11042 (Mar. 21, 2022) [87 FR 21334 (Apr. 11, 2022)] (“Proposing Release”).
1
•
Form 6-K (OMB Control No. 3235-0116).
2.
PURPOSE AND USE OF THE INFORMATION COLLECTION
The proposed amendments are intended to better inform investors about a registrant’s
exposure to climate-related risks, its governance and management of climate-related risks, and
any targets or goals to reduce those risks. Many investors requested that we revise our rules to
elicit better information about a registrant’s exposure to climate-related risks because the current
rules have not generated consistent, comparable, and decision-useful climate-related information
about their investments.
3.
CONSIDERATION GIVEN TO INFORMATION TECHNOLOGY
The forms that would be affected by the proposed amendments are filed electronically
with the Commission using the Commission’s Electronic Data Gathering and Retrieval
(“EDGAR”) system.
We are also proposing to require a registrant to tag the climate-related disclosures in
Inline eXtensible Business Reporting Language (“Inline XBRL”) in accordance with 17 CFR
232.405 (Rule 405 of Regulation S-T) and the EDGAR Filer Manual. The proposed
requirements would include block text tagging and detail tagging of narrative and quantitative
disclosures provided pursuant to Subpart 1500 of Regulation S-K and Article 14 of Regulation
S-X. Inline XBRL is both machine-readable and human-readable, which improves the quality
and usability of XBRL data for investors.3 Requiring Inline XBRL tagging of the disclosures
provided pursuant to these disclosure items would benefit investors by making the disclosures
more readily available and easily accessible to investors, market participants, and others for
aggregation, comparison, filtering, and other analysis, as compared to requiring a non-machine
readable data language such as ASCII or HTML.
4.
DUPLICATION OF INFORMATION
Business development companies (“BDCs”) could be subject to both these proposed rule
amendments and the proposed amendments in the Division of Investment Management’s
proposing release entitled “Enhanced Disclosures by Certain Investment Advisers and
Investment Companies about Environmental, Social, and Governance Investment Practices”
(“IM’s ESG Enhanced Disclosures rule proposal”)4 if both proposals were to be adopted.
Although the climate-related disclosures in this rule proposal would not duplicate the proposed
disclosures under IM’s ESG Enhanced Disclosures rule proposal, some of the proposed
disclosures in this rule proposal are similar, and would be complementary, to some of the
proposed disclosures in IM’s ESG Enhanced Disclosures rule proposal. To the extent that BDCs
would need to provide similar and complementary disclosures under both sets of rule
3
See Inline XBRL Filing of Tagged Data, Securities Act Release No. 10514 (June 28, 2018) [83 FR 40846 (Aug.
16, 2018)]. Inline XBRL allows filers to embed XBRL data directly into an HTML document, eliminating the
need to tag a copy of the information in a separate XBRL exhibit.
4
See Release No. 33-11068 (May 25, 2022).
2
amendments if adopted, some of the compliance costs could be duplicative. However, the
potential duplication should not result in a significant increase in compliance costs because
BDCs would be able to use some of the disclosures pursuant to this rule proposal when providing
certain of the disclosures pursuant to the IM’s Enhanced Disclosures rule proposal.5
5.
REDUCING THE BURDEN ON SMALL ENTITIES
The proposed rule amendments would affect some issuers that are small entities.
Commission staff has estimated that, as of December 2021, there are 1,004 registrants that may
be considered small entities that would be subject to the proposed amendments.
If adopted, some of the proposed amendments would apply to small entities to the same
extent as other entities, irrespective of size. For example, the proposed amendments would
require a registrant, including a small entity, to disclose certain climate-related information,
including data about their GHG emissions, when filing a Securities Act or Exchange Act
registration statement or Exchange Act annual or other periodic report. In particular, like larger
registrants, small entities would be required to disclose information about: the oversight of their
boards and management regarding climate-related risks; any material impacts of climate-related
risks on their consolidated financial statements, business, strategy, and outlook; their risk
management of climate-related risks; climate-related targets or goals, if any; and certain financial
statement metrics. In addition, like other registrants, small entities would be required to disclose
their Scopes 1 and 2 emissions.
We anticipate that the nature of any benefits or costs associated with the above proposed
amendments would be similar for large and small entities. We anticipate that the economic
benefits and costs likely could vary widely among small entities based on a number of factors,
such as the nature and conduct of their businesses, which makes it difficult to project the
economic impact on small entities with precision. As a general matter, however, we recognize
that the costs of the proposed amendments borne by the affected entities could have a
proportionally greater effect on small entities, as they may be less able to bear such costs relative
to larger entities.
While small entities would not be exempt from the full scope of the proposed
amendments, they would be exempt from the Scope 3 emissions disclosure requirements, which
would likely impose the greatest compliance burden for registrants due to the complexity of data
gathering, calculation, and assessment required for that type of emissions. Small entities would
also have a longer transition period to comply with the proposed rules than other registrants.
We believe that these accommodations would reduce the proposed rules’ compliance burden for
5
For example, under the proposed new subpart of Regulation S-K, a BDC would be required to disclose certain
of its GHG emissions (Scopes 1 and 2 emissions) and its GHG intensity in its registration statements and
Exchange Act annual report. Under IM’s Enhanced Disclosure rule proposal, a BDC that is an
environmentally-focused fund would be required to disclose the carbon footprint and the weighted average
carbon intensity (“WACI”) of the fund’s portfolio in its annual report. Because a BDC’s carbon footprint
depends in part on its Scopes 1 and 2 emissions, and its WACI is a particular expression of its GHG intensity, a
BDC registrant could use the measured data of its Scopes 1 and 2 emissions and its derived GHG intensity
undertaken to comply with these proposed rule amendments when calculating its carbon footprint and WACI
for purposes of complying with the IM’s Enhanced Disclosures proposed rule amendments.
3
small entities that, compared to larger registrants with more resources, may be less able to absorb
the costs associated with reporting of Scope 3 emissions and may need additional time to allocate
the resources necessary to begin providing climate-related disclosures.
The Commission requested comment on how the proposed amendments would affect
small entities and will continue to consider ways in the adopting release to ease the regulatory
burden on them, if appropriate.
6.
CONSEQUENCES OF NOT CONDUCTING COLLECTION
The affected forms were adopted under the Securities Act and Exchange Act and set forth
the disclosure requirements for registration statements and periodic reports filed by registrants to
help investors make informed investment and voting decisions. Less frequent collection would
deprive investors of access to information that is important to these decisions.
7.
SPECIAL CIRCUMSTANCES
There are no special circumstances in connection with the proposed amendments.
8.
CONSULTATIONS WITH PERSONS OUTSIDE OF AGENCY
In March 2021, Acting Chair Allison Herren Lee requested public input on climate
disclosure from investors, registrants, and other market participants. The Acting Chair solicited
input on several issues, including how the Commission could best regulate disclosure concerning
climate change in order to provide more consistent, comparable, and reliable information for
investors. The Commission received approximately 600 unique letters and over 5800 form
letters in response to the Acting Chair’s request for public input. Commission staff considered
these letters when drafting the proposed rule amendments. Commission staff also met and
consulted with some of these commenters, which included representatives of accounting and
audit firms, industry groups, investor groups, registrants, non-governmental organizations,
professional climate advisors, professional investment advisors and investment management
companies, and climate disclosure standard-setters. The Commission is currently soliciting
public comment on the proposed new “collection of information” requirements and the
associated paperwork burdens.
9.
PAYMENT OR GIFT TO RESPONDENTS
No payment or gift has been provided to any respondents.
10.
CONFIDENTIALITY
All of the affected collections of information filed with the Commission are available to the
public.
4
11.
SENSITIVE QUESTIONS
No information of a sensitive nature would be required in connection with the proposed
amendments. These information collections collect basic Personally Identifiable Information
(PII) that may include a name and job title. However, the agency has determined that the
information collections do not constitute a system of record for purposes of the Privacy Act.
Information is not retrieved by a personal identifier. In accordance with Section 208 of the EGovernment Act of 2002, the agency has conducted a Privacy Impact Assessment (“PIA”) of the
EDGAR system, in connection with the affected collections of information. The EDGAR PIA,
published on March 22, 2023, is provided as a supplemental document and is also available at
https://www.sec.gov/privacy.
12. and 13.
ESTIMATES OF HOURS AND COST BURDENS
The Commission anticipates that the proposed new disclosure and submission
requirements will increase the burdens and costs for affected registrants. The Commission
derived its burden hour and cost estimates by estimating the average amount of time it would
take a registrant to prepare and review the required disclosure and submission, as well as the
average hourly rate for outside professionals who assist with such preparation. All of these
burden estimates incorporate the proposed tagging requirements in Rule 405 of Regulation S-T.
The proposed amendments would add disclosure requirements comprising three
categories of disclosure:
•
•
•
climate-related disclosures regarding governance, strategy, and risk management, which
would be largely qualitative;
financial statement metrics, which would be largely quantitative; and
GHG emissions metrics and targets, which would include both quantitative and
qualitative disclosure.
U.S. registrants filing Securities Act registration statements on Forms S-1, S-4, and S-11,
and foreign private issuers filing Securities Act registration statements on Forms F-1 and F-4,
would be required to include the above climate-related disclosures. The proposed amendments
would further require U.S. registrants and foreign private issuers to include the above disclosures
in their Exchange Act annual reports filed, respectively, on Forms 10-K and 20-F and in
Exchange Act registration statements filed, respectively, on Forms 10 and 20-F. Registrants
would be required to include the climate-related information required under proposed new
subpart 1500 of Regulation S-K in a part of the registration statement or annual report that is
separately captioned as Climate-Related Disclosure. Registrants would be required to include
the climate information required under proposed new Article 14 of Regulation S-X in a note to
the financial statements, which would be subject to audit. Further, accelerated filers and large
accelerated filers would be required to include an attestation report covering their Scopes 1 and 2
emissions disclosure, subject to phase-ins.6 In addition, U.S. registrants and foreign private
6
Following a one-year phase-in period in which no attestation report would be required, for filings made for the
second and third fiscal years following the compliance date for the GHG emissions disclosure requirement,
5
issuers would be required to report material changes to the climate information disclosed in their
Exchange Act reports on, respectively, Forms 10-Q and 6-K.
Smaller reporting companies (“SRCs”), which comprise 50 percent of affected domestic
filers, would bear a lesser compliance burden because those registrants would not be subject to
the proposed disclosure requirement pertaining to Scope 3 emissions, which, of the three types of
GHG emissions, poses the greatest challenge to calculate and report. We accordingly estimate
that the increase in the PRA burden pertaining to the GHG emissions requirement for SRCs
filing on domestic forms would be approximately 50% less than the increased burden for the
GHG emissions requirement for non-SRC registrants. Smaller foreign private issuers that file
on the foreign private issuer forms would not be eligible for this adjustment because those
foreign private issuers are excluded from the definition of, and therefore cannot be, SRCs.7
We have assumed a 25 percent reduction in hour and cost estimates for the work required
to comply with the GHG emissions metrics and targets disclosure requirement in Year 2
compared to Year 1 because initial implementation of the metrics and targets framework would
not need to be repeated. We also have assumed a 10 percent reduction in the hour and cost
estimates for preparing and providing the climate-related disclosures regarding governance,
strategy, and risk management in Years 2 through 6 compared to Year 1. We believe that this
assumption is reasonable because the burden hours and costs associated with becoming familiar
with these largely qualitative disclosure topics would not need to be repeated. We believe that
the reduction in the compliance burden and costs for the metrics and targets disclosure
requirement would be greater than the reduction for the other climate-related disclosure topics
because the initial work to implement a climate data collection and reporting framework to
comply with the metrics and targets requirement would be greater than the initial framework
required for the other disclosure requirements.
Table 1 summarizes the estimated changes in burden attributable to the new items of
disclosure pursuant to the proposed amendments for the affected forms for non-SRC and SRC
registrants. A detailed description of the sources of the estimates and how they were calculated
can be found in Section V.B of the Proposing Release.
Table 1. Estimated Paperwork Burden Effects of the Proposed Amendments Per Non-SRC
and SRC Registrant8
large accelerated filers and accelerated filers would be required to obtain an attestation report for their Scopes 1
and 2 emissions disclosure, at minimum, at a limited assurance level. Commencing with the fourth fiscal year
following the compliance date and thereafter, large accelerated filers and accelerated filers would be required to
obtain an attestation report covering their Scopes 1 and 2 emissions disclosure at a reasonable assurance level.
In order to capture three years of the cost of a reasonable assurance attestation report required for accelerated
filers and large accelerated filers, which requirement does not commence until the fourth fiscal year following
the proposed rules’ compliance date, we have used a six-year average when calculating the estimated paperwork
burden effects of the proposed rules.
7
See, e.g., Instruction 2 to the definition of smaller reporting company under 17 CFR 230.405.
8
All numbers are rounded to the nearest whole number.
6
Collections of
Information
Proposed
Disclosure Item
Estimated PRA
Burden Hour
Effect per NonSRC Registrant
Estimated PRA
Burden Hour Effect
per SRC Registrant
Estimated PRA
Burden Hour
Effect per NonSRC Registrant
(For each Year 2
through 6)
Forms S-1,
S-4, S-11,
10, and 10-K
Climate-related
disclosures
regarding
governance,
strategy, and risk
management
Financial statement
metrics
Estimated PRA
Burden Hour
Effect for SRC
Registrants
(For each Year 2
through 6)
Estimated PRA
Burden Hour
Effect per NonSRC Registrant
(6 Year
Average)
Estimated PRA
Burden Hour
Effect per SRC
Registrant
Estimated
Average Annual
Assurance Costs
for Climaterelated Financial
Statement
Metrics
(6 Year Average)
Estimated Average
Annual Assurance
Costs for Scopes 1
and 2 Emissions
Disclosure per AF9
(6 Year Average)
(6 Year
Average)
(Year 1)
(Year 1)
+2,217 hrs.
+2,217 hrs.
+1,995 hrs.
+1,995 hrs.
+2,032 hrs.
+2,032 hrs.
+70 hrs.
+70 hrs.
+63 hrs.
+63 hrs.
+64 hrs.
+64 hrs.
+2,151 hrs.
+1,076 hrs.
+1,613 hrs.
+807 hrs.
+1,703 hrs.
+852 hrs.
+3,671 hrs.
+2,865 hrs.
+3,799 hrs.
+2,948 hrs.
+1,995 hrs.
NA
+2,032 hrs.
Estimated
Average
Annual
Assurance Costs
for Scopes 1 and
2 Emissions
Disclosure per
LAF10
(6 Year Average)
+$15,00011
+$52,500
$124,167
+$15,000
+$52,500
$124,167
+$15,000
+$52,500
$124,167
GHG emissions
metrics and targets
Total
+4,438 hrs.
+3,363 hrs.
h
Forms
F-1, F-4, and 20F
Climate-related
disclosures
regarding
governance,
strategy, and risk
management
.
+2,217 hrs.
N
A
Financial statement
metrics
+63 hrs.
+64 hrs.
+70 hrs.
GHG emissions
metrics and targets
.
7
NA
+1,703 hrs.
Total
Forms 10-Q and
6-K
Material change to
10-K/20-F
+2,151 hrs.
+1,613 hrs.
+4,438 hrs.
+3,671 hrs.
+3,799 hrs.
+40 hrs.
+33 hrs.
0
+$15,000
0
+$52,500
0
9
“AF” refers to Accelerated Filer.
10
“LAF” refers to Large Accelerated Filer.
11
Commission staff derived the estimate for the incremental audit fees associated with the financial statement metrics by multiplying the median audit fees for
the financial statements (approx. $690,000) by the estimated average percentage increase in audit fees associated with the financial statement metrics (just
over 2 percent) and rounded up to $15,000. The estimated average percentage increase associated with the financial statement metrics is not expected to be
large because much of the additional audit work would consist of reviewing the breakout of climate-related metrics from income, expenses, expenditures and
other line items that are already required to be reviewed under the general audit of the financial statements.
8
$124,167
0
When determining the paperwork burden of the proposed amendments, as is typically the
case for PRA purposes, we allocated the burden between internal burden hours and outside
professional costs. The next table sets forth the percentage estimates we used for the burden
allocation for each affected collection of information. They are the percentage estimates
typically assumed for this purpose. We also estimated that the average cost of retaining outside
professionals is $400 per hour.12
Table 2. Standard Estimated Burden Allocation for Specified Collections of
Information
Collection of
Information
Forms S-1, F-1,
S-4, F-4, S-11,
10, and 20-F
Forms 10-K,
10-Q, and 6-K
Internal
Outside Professionals
25%
75%
75%
25%
The next table below illustrates the estimated incremental and aggregate increase in
paperwork burden resulting from the proposed amendments. These estimates represent the
average burden for all issuers, both large and small. In deriving our estimates, we recognized
that the burdens will likely vary among individual registrants based on a number of factors,
including the nature of their business, the size and complexity of their operations, and whether
they are subject to similar climate-related disclosure requirements in other jurisdictions or
already preparing similar disclosures on a voluntary basis.
The burden increase estimates for each collection of information were calculated by
multiplying the number of responses by the increased estimated average amount of time it would
take to prepare and review the disclosure required under the affected collection of information.
Since 50 percent of the domestic filers in 2020 were non-SRCs and 50 percent were SRCs, we
assumed for purposes of our PRA estimates that 50 percent of each domestic collection of
information was filed by non-SRCs and 50 percent by SRCs.
12
We recognize that the costs of retaining outside professionals may vary depending on the nature of the
professional services, but for purposes of this PRA analysis, as is typically the case, we estimated that such
costs would be an average of $400 per hour.
9
Table 3. Calculation of the Incremental Change in Burden Estimates of Current Responses Resulting from the
Proposed Amendments13
Collection of
Information
Filed By
Number of
Estimated
Affected
Respondents
Burden Hour
Annual Increase
per Affected
Respondent
Increase in Burden
Hours for Affected
Respondents
(B)
(C) = (A) x (B)
(A)
S-1
S-1
S-1 (Total)
S-4
S-4
S-4 (Total)
S-11
S-11
S-11 (Total)
10
10
10 (Total)
10-K
10-K
10-K (Total)
10-Q
10-Q
10-Q (Total)
F-1
F-4
20-F
6-K
Non-SRCs
SRCs
Non-SRCs
SRCs
Non-SRCs
SRCs
Non-SRCs
SRCs
Non-SRCs
SRCs
Non-SRCs
SRCs
Both
Both
Both
Both
447
447
894
294
294
588
34
33
67
108
108
216
4,146
4,146
8,292
11,463
11,462
22,925
66
39
729
34,794
Increase in
Internal Burden
Hours for
Affected
Respondents
(D) = (C) x 0.25
or 0.75
3,799
2,948
3,799
2,948
3,799
2,948
3,799
2,948
3,799
2,948
33
33
3,799
3,799
3,799
33
1,698,153
1,317,756
3,015,909
1,116,906
866,712
1,983,618
129,166
97,284
226,450
410,292
318,384
728,676
15,750,654
12,222,408
27,973,062
378,279
378,246
756,525
250,734
148,161
2,769,471
1,148,202
Increase in Professional
Hours for Affected
Respondents
(E) = (C) x
0.75 or 0.25
Climate-Related
Financial
Statement Metrics
Assurance Costs
for
Affected
Respondents14
(F) = (A) x
$15,000
GHG
Emissions
Assurance
Costs for AFs15
(G) = (A) x
0.11 or 0.15
x $52,500
GHG
Emissions
Assurance
Costs for
LAFs16
(H) = (A) x
0.31 or 0.37 x
$124,167
Increase in
Professional Costs
for Affected
Respondents
(I) = (E) x $400 +
(F) + (G) + (H)
753,977
2,261,932
$13,410,000
$5,145,000
$34,394,259
$957,722,059
495,905
1,487,714
$8,820,000
$3,412,500
$22,598,394
$629,916,494
56,613
169,838
$1,005,000
$367,500
$2,607,507
$71,915,207
182,169
546,507
$3,240,000
$1,260,000
$8,319,189
$231,421,989
6,993,266
$124,380,000
$47,880,000
$319,233,357
$3,288,799,757
189,131
188,051
111,121
2,077,103
287,051
0
$990,000
$585,000
$10,935,000
0
0
$525,000
$315,000
$5,722,500
0
0
$2,980,008
$1,738,338
$33,525,090
0
$75,652,400
$79,715,408
$47,086,738
$881,023,790
$114,820,400
20,979,797
567,394
62,684
37,040
692,368
861,152
13
All numbers are rounded to the nearest whole number.
14
We have not assumed assurance costs for Form 10-Q or Form 6-K because these forms typically have only marginal assurance costs. We expect these forms to be filed in the
2nd year, at the earliest.
15
AFs filed 11% of domestic forms and 15% of foreign private issuer forms in 2020.
16
LAFs filed 31% of domestic forms and 37% of foreign private issuer forms in 2020.
10
14.
COSTS TO FEDERAL GOVERNMENT
The annual cost of reviewing and processing disclosure documents, including registration
statements, post-effective amendments, annual reports, and other filings of operating companies
amounted to $129,168,390 in fiscal year 2022, based on the Commission’s computation of the
value of staff time devoted to this activity and related overhead.
15.
REASON FOR CHANGE IN BURDEN
As explained in greater detail in Items 1, 12 and 13 above, the proposed rule
amendments, if adopted, would result in changes in the paperwork burden for many of the
Securities Act and Exchange Act forms filed by domestic and foreign private issuer registrants.
The estimated increases in paperwork burden for the affected forms would be due to the new
climate-related disclosure requirements under Regulation S-K and Regulation S-X that would
affect both domestic and foreign private issuer registrants alike.
The table below illustrates the program change expected to result from the proposed rule
amendments together with the total requested change in reporting burden and costs. We estimate
that the proposed amendments would change the burden per response, but not the frequency, of
the existing collections of information.
11
Table 4. Requested Paperwork Burden under the Proposed Amendments
Collection of
Information
Current Burden
Current
Annual
Responses
Current
Internal
Burden
Hours
Program Change
Current External
Cost Burden
No. of
Affected
Responses
Change in
Internal
Burden
Hours
Requested Change in Burden
Change in
External
Costs
Internal
Burden
Hours
External Cost
Burden
(G)
(H) = (B) +
(E)
(I) = (C) + (F)
(A)
(B)
(C)
(D)
(E)
S-1
898
141,978
$174,015,643
898
753,977
$957,722,059
898
895,955
$1,131,737,702
S-4
588
560,988
$675,605,379
588
495,905
$629,916,494
588
1,056,893
$1,305,521,873
S-11
67
12,101
$14,790,168
67
56,613
$71,915,207
67
68,714
$86,705,375
10
216
10,821
$12,851,488
216
182,169
$231,421,989
216
192,990
$244,273,477
10-K
8,292
13,988,811
$1,835,594,519
8,292
20,979,797
$3,288,799,757
8,292
34,968,608
$5,124,394,276
10-Q
22,925
3,098,084
$410,257,154
22,925
567,394
$75,652,400
22,925
3,665,478
$485,909,554
F-1
66
26,571
$32,130,375
66
62,684
$79,715,408
66
89,255
$111,845,783
F-4
39
13,999
$17,013,425
39
37,040
$47,086,738
39
51,039
$64,100,163
20-F
729
479,303
$576,533,425
729
692,368
$881,023,790
729
1,171,671
$1,457,557,215
6-K
34,794
227,031
$30,270,780
34,794
861,152
$114,820,400
34,794
1,088,183
$145,091,180
18,559,687
$3,779,062,356
24,689,099
$6,378,074,242
Total
12
(F)
Annual
Responses
43,248,786
$10,157,136,598
Form S-1 Short Statement
If adopted, the proposed amendments would require enhanced and standardized climaterelated disclosures for investors in a registrant’s registration statements and periodic reports,
such as its registration statement on Form S-1, including information about a registrant’s material
climate-related risks, governance of climate-related risks, greenhouse gas emissions, and
financial statement metrics.
The Commission estimates that the amendments would result in an increase in the
paperwork burden of affected entities. For purposes of the PRA, the Commission estimates that,
for Form S-1, the proposed amendments would result in an increase of 753,977 internal burden
hours and $957,722,059 for the services of outside professionals.
13
Form S-4 Short Statement
If adopted, the proposed amendments would require enhanced and standardized climaterelated disclosures for investors in a registrant’s registration statements and periodic reports,
such as its registration statement on Form S-4, including information about a registrant’s material
climate-related risks, governance of climate-related risks, greenhouse gas emissions, and
financial statement metrics.
The Commission estimates that the amendments would result in an increase in the
paperwork burden of affected entities. For purposes of the PRA, the Commission estimates that,
for Form S-4, the proposed amendments would result in an increase of 495,905 internal burden
hours and $629,916,494 for the services of outside professionals.
14
Form S-11 Short Statement
If adopted, the proposed amendments would require enhanced and standardized climaterelated disclosures for investors in a registrant’s registration statements and periodic reports,
such as its registration statement on Form S-11, including information about a registrant’s
material climate-related risks, governance of climate-related risks, greenhouse gas emissions,
and financial statement metrics.
The Commission estimates that the amendments would result in an increase in the
paperwork burden of affected entities. For purposes of the PRA, the Commission estimates that,
for Form S-11, the proposed amendments would result in an increase of 56,613 internal burden
hours and $71,915,207 for the services of outside professionals.
15
Form 10 Short Statement
If adopted, the proposed amendments would require enhanced and standardized climaterelated disclosures for investors in a registrant’s registration statements and periodic reports,
such as its registration statement on Form 10, including information about a registrant’s material
climate-related risks, governance of climate-related risks, greenhouse gas emissions, and
financial statement metrics.
The Commission estimates that the amendments would result in an increase in the
paperwork burden of affected entities. For purposes of the PRA, the Commission estimates that,
for Form 10, the proposed amendments would result in an increase of 182,169 internal burden
hours and $231,421,989 for the services of outside professionals.
16
Form 10-K Short Statement
If adopted, the proposed amendments would require enhanced and standardized climaterelated disclosures for investors in a registrant’s registration statements and periodic reports,
such as its annual report on Form 10-K, including information about a registrant’s material
climate-related risks, governance of climate-related risks, greenhouse gas emissions, and
financial statement metrics.
The Commission estimates that the amendments would result in an increase in the
paperwork burden of affected entities. For purposes of the PRA, the Commission estimates that,
for Form 10-K, the proposed amendments would result in an increase of 20,979,797 internal
burden hours and $3,288,799,757 for the services of outside professionals.
17
Form 10-Q Short Statement
If adopted, the proposed amendments would require enhanced and standardized climaterelated disclosures for investors in a registrant’s registration statements and periodic reports,
such as its periodic report on Form 10-Q, including information about a registrant’s material
climate-related risks, governance of climate-related risks, greenhouse gas emissions, and
financial statement metrics.
The Commission estimates that the amendments would result in an increase in the
paperwork burden of affected entities. For purposes of the PRA, the Commission estimates that,
for Form 10-Q, the proposed amendments would result in an increase of 567,394 internal burden
hours and $75,652,400 for the services of outside professionals.
18
Form F-1 Short Statement
If adopted, the proposed amendments would require enhanced and standardized climaterelated disclosures for investors in a registrant’s registration statements and periodic reports,
such as its registration statement on Form F-1, including information about a registrant’s material
climate-related risks, governance of climate-related risks, greenhouse gas emissions, and
financial statement metrics.
The Commission estimates that the amendments would result in an increase in the
paperwork burden of affected entities. For purposes of the PRA, the Commission estimates that,
for Form F-1, the proposed amendments would result in an increase of 62,684 internal burden
hours and $79,715,408 for the services of outside professionals.
19
Form F-4 Short Statement
If adopted, the proposed amendments would require enhanced and standardized climaterelated disclosures for investors in a registrant’s registration statements and periodic reports,
such as its registration statement on Form F-4, including information about a registrant’s material
climate-related risks, governance of climate-related risks, greenhouse gas emissions, and
financial statement metrics.
The Commission estimates that the amendments would result in an increase in the
paperwork burden of affected entities. For purposes of the PRA, the Commission estimates that,
for Form F-4, the proposed amendments would result in an increase of 37,040 internal burden
hours and $47,086,738 for the services of outside professionals.
20
Form 20-F Short Statement
If adopted, the proposed amendments would require enhanced and standardized climaterelated disclosures for investors in a registrant’s registration statements and periodic reports,
such as its registration statement or annual report on Form 20-F, including information about a
registrant’s material climate-related risks, governance of climate-related risks, greenhouse gas
emissions, and financial statement metrics.
The Commission estimates that the amendments would result in an increase in the
paperwork burden of affected entities. For purposes of the PRA, the Commission estimates that,
for Form 20-F, the proposed amendments would result in an increase of 692,368 internal burden
hours and $881,023,790 for the services of outside professionals.
21
Form 6-K Short Statement
If adopted, the proposed amendments would require enhanced and standardized climaterelated disclosures for investors in a registrant’s registration statements and periodic reports,
such as its report on Form 6-K, including information about a registrant’s material climaterelated risks, governance of climate-related risks, greenhouse gas emissions, and financial
statement metrics.
The Commission estimates that the amendments would result in an increase in the
paperwork burden of affected entities. For purposes of the PRA, the Commission estimates that,
for Form 6-K, the proposed amendments would result in an increase of 861,152 internal burden
hours and $114,820,400 for the services of outside professionals.
22
| File Type | application/pdf |
| File Modified | 2023-09-09 |
| File Created | 2023-09-09 |