The U.S. Chamber of Commerce released this month a set of ESG voluntary reporting best practices. By releasing its best practice guide, the Chamber makes clear that it believes further regulatory requirements mandating ESG disclosures are not warranted. A departure from a one-size-fits-all approach, the best practices guide asserts that each company should have the discretion to determine which ESG factors and related metrics are relevant to it without necessarily being tied to the various third-party frameworks and standards currently in existence. Finally, the best practices guide emphasizes that ESG reports need not be incorporated into filings with the SEC, nor should ESG information be required as part of an SEC filing if it is not “material”.
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