ESG and climate disclosure
ESG and climate disclosure requirements are hitting Defense & Government Contracting firms from two directions at once: federal procurement rules and securities-side mandates. The U.S. Securities and Exchange Commission's climate disclosure rule, finalized in March 2024, creates direct obligations for publicly traded defense contractors, while the U.S. Federal Acquisition Regulatory Council's proposed rule on greenhouse gas emissions reporting targets any contractor with $50 million or more in annual federal awards. Compliance teams in this sector are now reconciling those two disclosure frameworks against each other before contract cycles close.
Watch
- FAR Council GHG emissions reporting rule: applicability threshold and phased timeline
- SEC climate disclosure rule litigation status and any stayed provisions
- SBTi target-setting requirements surfacing in prime contractor supplier codes of conduct
- Department of Defense climate risk pilot programs that may feed future contract clauses
Recent material activity in Defense & Government Contracting
Active monitoring in place across Defense & Government Contracting. Material developments related to esg and climate disclosure will appear here as they are published.