Posted by Johann Nacario — March 19, 2024 — OSCRE International, the nonprofit organization focused on real estate data standards and effective data governance practice, just announced that in a 3-2 split decision, the Securities and Exchange Commission (SEC) has finalized rules initially proposed in March 2022 that require registrants to disclose certain climate-related information in registration statements and annual reports.
Over 20,000 comments were filed during the public comment period with many of them focused on the difficulty in obtaining Scope 3 emissions data. Separate and apart from the SEC rule, more than 60 local and state environmental reporting requirements have either already been approved or are under consideration that do include Scope 3 reporting requirements.
To help you navigate the new reporting mandate, the OSCRE website has a new resource page devoted to the topic of energy data and the SEC. The page includes a list of the five use cases in the Energy Data Standards, a chart to help you make the business case for implementation, and a link to the SEC-published Fact Sheet on this subject that includes phased-in compliance dates for reporting.
Need help building skills to meet the expanding reporting requirements? OSCRE has also developed an on-demand Effective Energy Data Management Practices Certificate Program that consists of ten, one-hour modules to help you build skills to collect, analyze and report environmental data. Developing these skills Is a critical component of your organization’s data strategy for reporting across a variety of jurisdictions.
To help you get started, OSCRE is offering a $100 discount when registering for this course — you can access it online when you schedule permits. Use discount code SEC100 at the time of registration to receive your discount. If you have more than 10 team members you’d like to register at one time, email OSCRE to get a group discount price. Don’t delay — this discount expires April 15, 2024.
Bill Harter, principal solutions advisor at Visual Lease (an OSCRE member firm) provided this perspective on the SEC Final Rule:
In the wake of the SEC Final Rule, it is essential to acknowledge that despite the Securities and Exchange Commission (SEC) stepping back from mandatory Scope 3 emissions reporting, businesses should not veer away from this responsibility. Numerous other jurisdictions, influencing companies operating within their purview, enforce the disclosure of Scope 3 emissions.
Given that a substantial portion of a company’s environmental footprint often stems from its real estate, equipment, and vehicles, focusing first on their lease portfolios will provide affected businesses with a strategic advantage. Leases are often considered a Scope 3 emission for companies, just as tenant activity can often be a Scope 3 emission for landlords.
The SEC actions do not eliminate the requirement to report these emissions under New York’s Local Law 97 or similar laws in states and municipalities across the country. By gathering, centralizing and analyzing these records, these companies will be able to accurately report on their environmental impact, and also, be empowered to successfully set and execute associated goals.
The OSCRE Energy Data Standards make significant progress towards enabling landlords and tenants to accurately report this information. This proactive approach not only aligns with global environmental expectations, but also fosters a culture of environmental stewardship within the business community.
Keep an eye on OSCRE’s Energy Data Standards & New SEC Reporting Requirements page for continued updates on this important topic.
