Template letter to request ISSB-aligned reporting from companies

Climate disclosure request letter

Introduction

Ongoing litigation and regulatory changes around climate disclosure regulations in large capital markets like the US and Canada continue to create uncertainty for both investors and issuers. Regardless of the outcome of such regulation, the PRI encourages investors to continue seeking disclosure of climate-related financial information in line with the standards of the IFRS Foundation’s International Sustainability Standards Board (“ISSB standards”).

Background: SEC and CSA regulations

The US Securities and Exchange Commission’s (SEC’s) climate disclosure rule was approved on 6 March 2024. Several states and industry groups immediately filed litigation against the SEC, seeking to overturn the rule, and shortly after, the SEC issued a voluntary stay of implementation, citing a desire to avoid regulatory uncertainty while the litigation proceeded. In March 2025, under Acting Chair Mark Uyeda, the SEC voted to end its legal defense of the rule. In response, 18 states and the District of Columbia filed a motion to hold the litigation in stasis, and asked the court for approval to defend the rule in lieu of the SEC. The SEC may seek to formally amend or rescind the rule in the future.

In Canada, the Canadian Securities Administrators (CSA) announced in April 2025 that it is pausing work on a new mandatory climate disclosure rule and amendments to existing diversity-related disclosure requirements. In December 2024, Canada’s independent financial reporting standards setter released the first voluntary set of sustainability disclosure standards, aligned with ISSB.

ISSB adoption

Developments with the SEC and CSA’s work do not reflect international trends in corporate reporting. In 2024, the PRI and partner organisations published a call to action encouraging relevant authorities to adopt ISSB-aligned reporting requirements, supported by 121 investors, companies, industry associations and stock exchanges. Already, more than 35 jurisdictions are using or are in the process of adopting ISSB standards into their regulatory frameworks. Within the US, several states have implemented or are considering their own disclosure frameworks, such as via California’s SB 253 and 261 or current proposals in New York.

Regardless of regulatory uncertainty in any particular jurisdiction, investor demand for reporting of climate-related financial information is here to stay. You may use the letter below to express that interest to your portfolio companies. Please consider the letter a template and include any additional information (including company-specific information) that you believe may be relevant to this type of engagement.