AP7 has submitted a response to the U.S. Securities and Exchange Commission (SEC), opposing the agency’s proposal to rescind the climate disclosure rules adopted in 2024. Removing the rules would risk impairing investors’ ability to assess climate-related financial risks and make well-informed investment decisions.
On 3 June 2026, the SEC proposed rescinding its climate-related disclosure rules. Although the rules have not yet entered into force due to ongoing legal challenges, they would require listed companies to provide standardized disclosures on climate-related risks, governance, greenhouse gas emissions and transition plans in their public reporting.
The SEC argues that the rules exceed the agency’s statutory authority and impose costs that are disproportionate to their benefits.
Important Information for Long-Term Investors
In its comment letter, AP7 emphasizes that climate change creates significant financial risks and opportunities that affect companies’ value creation and long-term returns. AP7 is Sweden’s largest pension fund and one of Europe’s largest, managing approximately USD 150 billion (SEK 1.5 trillion) in assets. More than 60 percent of the fund’s equity holdings are invested in North American companies.
”Comparable and reliable climate reporting is an important prerequisite for investors to assess risks, make informed investment decisions and contribute to an efficient allocation of capital,” says Charlotta Dawidowski Sydstrand, Head of Sustainability at AP7.
AP7 uses climate-related information in its investment analysis, stewardship activities, proxy voting, and in assessing physical, regulatory and systemic risks across the portfolio.
Higher Costs and Reduced Comparability
AP7 also notes that climate reporting by U.S. companies is often less comprehensive and less comparable than reporting by companies in other jurisdictions. Rescinding the rules would therefore make relevant information more difficult and costly for investors to obtain.
Against this background, AP7 urges the SEC to withdraw its proposal to rescind the climate disclosure rules.
Read AP7’s comment letter here