Overview

CAQ looked at the most recent SEC Form 10-K for S&P 500 companies as of June 2022.¹

We analyzed 10-Ks from S&P 500 companies to understand what companies disclosed in their SEC filing about:

• Climate-related information (e.g., mention of climate change)
• Greenhouse gas emissions (Scope 1, 2, and 3)
• Net-zero and carbon neutral commitment

This analysis was solely focused on information disclosed in an S&P 500 company’s SEC Form 10-K, and does not contemplate climate-related information communicated by companies in information outside of their SEC Form 10-K.

CAQ observed that the majority of S&P 500 companies mention climate-related information in their 10-K.

• The number of S&P 500 companies mentioning climate-related information in their 10-K increased roughly 18% from a similar analysis of 2020 10-Ks.
• There were a little over 40 S&P 500 companies that did not mention climate-related information at all in their 10-K.

Overall, we found that when disclosures in an S&P 500 company’s 10-K included mention of climate-related information, the types of information included in the climate-related disclosures varied from company to company.

• We observed that some companies disclose actual emissions and reduction amounts, and others only disclose their goals for future emissions reductions.
• While some companies disclose climate related costs, those disclosures vary from capital expenses, research and development (R&D), or regulatory and compliance costs.
• We observed net zero and carbon neutral commitments disclosed in 10-Ks varied from company to company.
  • Some S&P 500 companies disclose net zero or carbon neutral commitments over scope 1 and 2 GHG emissions by a certain date, whereas others disclose goals for Scope 3.
  • Most S&P 500 companies did not disclose a net zero or carbon neutral commitment in their 10-K.

Section of 10-K where climate-related information is mentioned

The majority of S&P 500 companies that mention climate-related information in their 10-K do so in Item 1A. Risk Factors and/or Item 1. Business.

• Less common sections of the Form 10-K where S&P 500 companies mentioned climate-related information included Item 2. Properties, Item 3. Legal Proceedings, Item 7A. Qualitative and Quantitative Disclosure About Market Risk, Item 11. Executive Compensation, Item 15. Exhibits or Appendices.

Monetary climate-related information

Of the 453 S&P 500 companies that mentioned climate-related information in their 10-K, around 40 companies provided financial figures for their R&D, capital expenses, sustainable bonds, or other climate related costs.

Some S&P 500 companies described various climate-related monetary figures in different items and different topics in their 10-K, mostly in Item 1. Business, Item 7. MD&A, and less in Item 8. Financial Statements.

Some S&P 500 companies disclose capital expenses associated with climate change in Item 1. Business, whereas other companies may disclose R&D or compliance costs in Item 7. MD&A.

Climate-related mentions in the financial statements

Most mentions of climate-related information in Item 8. Financial Statements were included in a commitment and contingencies footnote.

• In some instances, we observed a discussion of lawsuits, consumer trends, and/or regulatory activities that were climate-related.
• We did observe some instances where S&P 500 companies disclosed more details about their climate-related commitments or strategies.
  • For example, one company described their carbon-neutral goals including dates and interim goals. Further, they disclosed that these goals could result in changes to the useful lives of certain assets. Ultimately, they were unable to currently estimate the financial impact.

We observed several disclosures of climate change in footnotes that described terms of green bonds.

We observed a critical audit matter communicated in the auditor’s report that mentioned climate change:

• Identification and valuation of long-lived asset impairments and re-evaluation of useful lives was communicated as a CAM. “…auditing the company’s re-evaluation of useful lives required a high level of subjectivity, particularly as it related to the company’s coal generation assets given the company’s decarbonization initiatives and the potential risks associate with climate change that have led to increased regulation and other actions…”

GHG emissions-related mentions

We examined whether there was a mention of scope 1, 2, and/or 3 GHG emissions, status, and/or objectives in their 10-K.

• S&P 500 companies that disclose their scope 1, 2, and/or 3 emissions tended to also provide some quantitative information such as their actual carbon emissions for a period of time, their actual reductions in emissions, and/or projected reductions in emissions by a certain date.

Endnotes

1. The data herein reflects the S&P 500 index from 2021 and the company’s most recent SEC Form 10-K as of June 30, 2022.