The Disclosure of Greenhouse Gases by Companies: Differences between Africa and the United States of America - European Business Law Review View The Disclosure of Greenhouse Gases by Companies: Differences between Africa and the United States of America by - European Business Law Review The Disclosure of Greenhouse Gases by Companies: Differences between Africa and the United States of America 36 4

On 6 March 2024, the Securities and Exchange Commission (SEC) proposed and adopted an environmental disclosure rule (Enhancement and Standardisation of Climate-Related Disclosures for Investors). The rule and its explanation consist of 886 pages; consequently, this article attempts to illustrate briefly the environmental metrics or factors that comprise this rule and which US companies have to report on in their audited financial statements. The SEC metrics for calculating and reporting greenhouse gas (GHG) emissions are largely based on the Greenhouse Gas Protocol and the Task Force on Climate Related Financial Disclosures (TCFD). In Africa, the Johannesburg Stock Exchange (JSE) in South Africa has introduced similar environmental metrics for GHG disclosures. In the future, South Africa’s Climate Change Bill, 2022, will empower the Minister to issue regulations that promote standardised environmental metrics for companies, similar to the SEC rule. This article also briefly focuses on the Corporate Sustainability Reporting Directive (CSRD).

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