climate-focused committee — is appropriate , or whether responsibility reasonably can be shouldered by an existing committee , such as the audit committee .
2 . Establish organizational responsibility for assessing the implications of the new rules for your company .
As noted above , this is a huge task that will require input from a multidisciplinary team , including legal , accounting , operations and possibly other personnel .
Identifying the right team and setting clear responsibilities and timelines are critical near-term tasks . 3 . Understand the timeline for compliance with the rules as it relates to your organization .
As noted above , the new rules provide a phase-in for compliance over several years based on a company ' s status as a large accelerated filer , an accelerated filer , a nonaccelerated filer , a smaller reporting company or an emerging growth company .
The fact sheet [ 3 ] on the final rules published by the SEC provides a helpful table , on Page 4 , detailing the phase-in periods for each type of SEC registrant .
4 . Understand the disclosures the new rules will require for your company based on its specific circumstances .
The new rules are highly prescriptive in many respects — although less prescriptive and more flexible than the rules as originally proposed — and are intended to produce consistent and comparable disclosures across the public company spectrum .
With a few important exceptions — e . g ., that nonaccelerated filers , smaller reporting companies and emerging growth companies are not required to disclose GHG emissions data — all public companies will need to assess required disclosure under all provisions of the rules .
That assessment , however , will need to be made in light of the company ' s specific circumstances , and there will be categories of required disclosures that are very relevant to some industries or companies , but of no or limited relevance to other industries or companies .
Additionally , many companies have been voluntarily disclosing information that is similar to some of the information required to be provided under the new rules , but there may be gaps between or differences in required disclosures and a company ' s current practices .
As companies begin to digest the new rules , it will make sense for them to drill down on the specific types of disclosures they will need to make . This includes whether Scope 1 or 2 emissions are " material " such that companies need to disclose them .
The new rules do not specifically define " material " for this purpose , but the SEC made clear in the adopting release for the new rules that it intends for materiality determinations to be made in accordance with the generally applicable standard under federal securities laws — i . e ., that information is material if a reasonable investor would consider the information important when making an investment or voting decision , or would view the information ( or its omission ) as having significantly altered the total mix of information made available .