Additionally , the climate-related risk disclosures required by the new rules may compel companies to devote significant resources to expanding the process by which they identify and assess climate-related risk . The new rules place a heightened emphasis on materiality — e . g ., the requirement noted above to disclose GHG emissions if such emissions are " material ."
To the extent not already in place , companies should begin building systems for making and documenting decisions around materiality in the specific context of climate-related information .
6 . Evaluate needs and strategy for retaining third parties to assist with disclosures , including for the attestation of GHG emissions data .
As noted above , for companies that are required to disclose Scope 1 or Scope 2 emissions data , the new rules eventually will require attestation regarding such emissions data by an independent third party that meets certain minimum qualifications .
While the attestation requirement does not apply until after the third year , a company , especially a large accelerated filer , that is required to disclose emissions data may wish to begin thinking about its options for third parties to handle the attestation , as they may be helpful in establishing the controls and procedures for collecting the data to ensure that the disclosure information being developed and gathered will be sufficient for attestors to provide the required assurance .
In addition to attestation services , companies should consider their potential need for and access to other third-party advisers to assist them with climate-related disclosures .
7 . Consider whether the disclosures required by the new rules warrant any changes to current , planned or contemplated climate-related activities .
As noted above , the new rules require detailed disclosures regarding several matters that may or may not be relevant to a particular company depending on things that the company may or may not have done in advance of the initial compliance date for the new rules .
These include whether a company has :
� Adopted a climate transition plan ;
� Set climate-related goals or targets ;
� Used carbon offsets or renewable energy credits in setting its goals or targets ;
� Used scenario analyses or other analytical tools in assessing climate-related risk ; or
� Used an internal carbon price .
Companies may wish to reassess their existing , planned or contemplated activities in these areas in view of the new disclosure requirements . It may be the case that a company would want to modify its activities in one or more of these areas when viewed through the lens of what the company ' s disclosures regarding such activities will look like under the new rules .
8 . Don ' t forget that climate-related disclosures may be required under existing SEC rules and interpretations .
With the work needed to prepare for compliance with a massive new disclosure regime for climate-