New Financial Accounting Standards

3 Months Ended

Mar. 31, 2024

Accounting Changes and Error Corrections [Abstract]

New Financial Accounting Standards

New Financial Accounting Standards

In March 2024, the SEC issued a final rule, The Enhancement and Standardization of Climate-Related Disclosures for Investors, that requires registrants to provide climate-related disclosures in annual reports. The rule was subjected to litigation upon its release, and multiple challenges to the rule are currently pending with the United States Court of Appeals for the Eight Circuit. As a result, the SEC has temporarily stayed its rule pending judicial review. The results of the legal challenges and potential SEC actions may materially alter the terms of the rule as described below.

Beginning with the 2025 annual report, the Companies would be required to provide additional disclosures in the Management Discussion and Analysis (MD&A) section of the SEC Form 10-K, and in the footnotes to the financial statements. The MD&A disclosures would describe material climate-related risks and their impacts, as well as board oversight of such risks. The footnote disclosures would quantify the impacts of severe weather events and other natural conditions, if material, and provide additional qualitative disclosures. Finally, the rule creates a new section of annual reports related to Scope 1 and Scope 2 greenhouse gas emission disclosures, beginning with the 2026 annual report. If any of the greenhouse gases specified in the rule is individually material, that would need to be separately disclosed. Qualitative disclosures related to the methodology, significant inputs and assumptions used to calculate GHG emissions are also required. The greenhouse gas emission disclosures would be subject to limited and then reasonable assurance for years beginning in 2029 and 2033, respectively.

The Companies are evaluating the requirements of the final rule, and closely monitoring legal developments. The Companies do not expect the final rule to have a material impact on results of operations, financial position, or liquidity. However, there are substantial disclosure requirements and the Companies have cross-functional working groups assessing the implications and implementing best practices.