Climate Disclosure Whiplash: What to Report When the Rule Is Paused

Even when rules pause, markets don’t.

The SEC voted to end its defense of its climate disclosure rules in 2025. Courts also moved to pause related litigation while the agency’s direction remained unsettled, with enforcement stayed.Some companies heard that as permission to stop reporting. That’s a mistake.

Why? Because climate risk has become underwriting logic: insurers price it, lenders diligence it, and investors compare it—especially for real assets, infrastructure-adjacent businesses, and portfolios exposed to regulatory shocks.

So what should businesses do in 2026?

Focus on three “credibility layers”:

1. Material risk narrative (what could hurt revenue/costs, and where).

   
   

2. Operational metrics you can defend (energy use, resilience measures, exposure).

   
   

3. Governance (who owns it, how decisions are made).

If you can’t audit it, don’t over-claim it. But if you ignore it, you’ll get priced as if you’re hiding it.

For OUM readers, this is also place-based. Buildings and districts facing flood risk, heat risk, or grid stress will see real impacts on capex, insurance, and tenant demand—regardless of federal disclosure politics.

The rule may be paused. The business risk isn’t.