With the comment period on the SEC’s proposal to rescind its 2024 climate disclosure rules now closed, the United States is on course to become the only major OECD market moving to remove, rather than refine, a federal investor-facing climate reporting framework.

That matters because climate disclosure is increasingly an investor-data issue, not simply a regulatory one. For global asset owners and managers, the key question is not which jurisdiction has the most demanding rules. It is where comparable, decision-useful climate information will be available, and where it will not.

The result may not be an end to climate disclosure by US companies. Many large issuers are likely to continue reporting in some form, whether because of investor expectations, California requirements, overseas regulation, lender demands, customer pressure or voluntary alignment with international standards. But that is different from having a common federal baseline.

Climate Disclosure Continues to Expand Across OECD Markets

Perhaps the most significant development of the past two years has been the consolidation of ISSB standards as the preferred foundation for new climate and sustainability disclosure regimes.

By January 2026, twenty-one jurisdictions had adopted ISSB standards on either a mandatory or voluntary basis, with more jurisdictions in the process of implementation. The details vary, but the broad direction of travel remains consistent across developed markets: investor-facing climate disclosure, increasing alignment with ISSB standards, phased implementation by company size, and assurance requirements that strengthen over time.

The European Union is an important example. The Omnibus reforms are often described as a retreat from sustainability reporting. In practice, they are better understood as a narrowing of the population caught by the Corporate Sustainability Reporting Directive, rather than a dismantling of the reporting architecture itself. The ESRS framework, assurance pathway and investor-information objective remain in place. The debate has shifted from whether climate disclosure should exist to how broad, complex and proportionate it should be.

That distinction matters. Across Europe, the UK, Australia and Japan, policymakers are not abandoning climate reporting. They are adjusting implementation, scope and timing around the common objective giving investors a more consistent baseline of climate-related information.

The United States is now moving in a different direction. The question is no longer whether climate disclosure frameworks exist across major markets. It is whether the US will remain part of that convergence.

Climate Disclosure Requirements Across Major OECD Markets

What Climate Disclosure Could Look Like by 2028

For investors, the practical question is what a global portfolio will look like three years from now if current policy trajectories hold.

The implications for investment analysis could be substantial. By 2028, a European investor may have access to more comparable and assured climate information from a mid-cap company in Sydney or Osaka than from a large-cap company in New York.

That is not necessarily a reflection of climate ambition. It is a reflection of the information environment available to investors making allocation, risk and stewardship decisions.

US Climate Disclosure: Fragmentation Rather Than Exemption

One assumption behind the rescission debate is that removing federal requirements would reduce reporting obligations for US issuers.

In practice, the effect may be more complicated.

Large US companies with European operations may still fall within the scope of CSRD. Companies doing business in California may be subject to state-level requirements. US issuers seeking access to international capital markets will increasingly encounter disclosure expectations shaped by ISSB-aligned frameworks in London, Tokyo, Singapore and elsewhere.

Many companies may also decide to use ISSB standards voluntarily. For large multinationals, that may be a practical response to investor requests, reporting efficiency and the need to communicate with global capital markets. A single voluntary ISSB-aligned report may be more useful than multiple bespoke responses to different stakeholder questionnaires.

But voluntary adoption has limits. It is likely to be uneven across sectors, market capitalisations and investor bases. Some companies may provide full ISSB-style disclosure. Others may provide selected metrics, partial narrative reporting or climate information that is difficult to reconcile with peers. Assurance may also vary significantly.

What potentially disappears, therefore, is not climate reporting itself. It is a common national reference point.

For investors comparing companies across markets, that distinction matters. Disclosure can exist in abundance and still be difficult to use if it is produced under different assumptions, standards, boundaries and levels of assurance.

Why the US position matters for investors

The SEC’s 2024 rules were already narrower than many international frameworks. They did not require Scope 3 emissions disclosure, and they focused on information considered material to investors. Even so, they would have created a federal structure around climate-related governance, risk management, targets, transition plans and emissions reporting for US registrants.

Rescinding those rules would not simply place the US on a slower implementation path. It would leave the world’s largest capital market without a federal climate disclosure baseline at a time when other major markets are moving towards more comparable investor-facing regimes.

That would have consequences beyond compliance. It could affect the quality of cross-market analysis, the consistency of climate risk pricing, the usefulness of stewardship conversations and the ability of investors to compare companies operating in similar sectors but reporting under different expectations.

What comes next

A final SEC decision is unlikely before late 2026 or early 2027. Whatever the outcome, the broader international trend appears clear. Most major markets continue to move towards mandatory, investor-focused climate disclosure built around increasingly comparable standards and assurance requirements.

The models will not be identical. The EU will not look exactly like Australia. The UK will not look exactly like Japan. Some jurisdictions will phase requirements more slowly, narrow the population of companies in scope or introduce reliefs for specific disclosures.

But the common direction, and the common ISSB reference point, remains important. Investors are likely to have access to increasingly comparable climate information across much of Europe, Australia and parts of Asia and the Americas. If the SEC proceeds with rescission, the practical question will not be whether US companies disclose climate information at all. It will be whether investors receive that information on a sufficiently consistent basis to compare companies across markets.

On present trajectories, the United States risks becoming the exception not because climate disclosure disappears, but because comparable climate disclosure may become harder to find.