FOR IMMEDIATE RELEASE
August 3, 2026
American Energy Association Urges SEC to Rescind Biden-Era Climate Disclosure Rule, Calls Out Compelled Speech and Regulatory Overreach
Comment letter argues the 2024 climate disclosure rule exceeds the Commission’s statutory authority, violates the First Amendment, and would cost companies nearly $8 billion upfront with billions more every year
WASHINGTON, D.C. — The American Energy Association filed formal comments with the U.S. Securities and Exchange Commission supporting its proposed rescission of the 2024 climate rule, “Enhancement and Standardization of Climate-Related Disclosures for Investors” (File No. S7-2026-19), calling it a welcome return to the disclosure framework that has anchored federal securities law for nearly a century.
The letter argues the rule never had statutory footing. Congress authorized the Commission to require disclosure of financially material information bearing on the decisions of reasonable investors, and the association’s comments say the rule fails that test, resting instead on the general “public interest” language in the securities laws rather than any defined authority to mandate climate-specific reporting.
The comments also raise a First Amendment objection. Because climate change is “among the most contested issues in contemporary public debate,” the letter states, the rule “conscripts issuers into that debate, forcing them to adopt frameworks and convey messages they may reject or prefer to leave unsaid,” a form of compelled speech the association argues the Commission cannot justify.
On cost, the letter cites the Commission’s own numbers: rescinding the rule will avoid $7.9 billion in initial compliance outlays and between $1.7 billion and $5.6 billion in recurring annual expenditures, figures the association says likely understate the true savings since the rule was stayed before ever taking effect.
The association is also urging the Commission to go further than the current proposal by rescinding its 2010 Commission Guidance Regarding Disclosure Related to Climate Change and by stating that rescission of the rule preempts state efforts to impose similar climate-disclosure mandates on companies.
Read the full comment letter here
About the American Energy Association
The American Energy Association is a leading advocacy organization committed to advancing affordable, reliable, and abundant American energy. We represent the interests of energy producers, consumers, and businesses across the country.
Media Contact:
Hon. Jason Isaac
American Energy Association
512-815-2207
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