On September 12, 2025, the Eighth Circuit Court of Appeals ordered that the proceedings in Iowa v. SEC – the case challenging the Securities and Exchange Commission’s (SEC) landmark climate disclosure rules – remain paused until the SEC either reconsiders the rules through the notice-and-comment rulemaking process or decides to

Continue Reading Eighth Circuit pauses SEC climate rules litigation pending SEC action

The August issue of Horizon is now available, covering an array of late-breaking developments in ESG law. Among the developments we cover in this issue: the coming reporting deadline under California’s SB 261; the €1 million greenwashing fine levied against Shein’s web provider; latest developments around the Endangerment Finding; the

Continue Reading Recent ESG legal developments

The Securities and Exchange Commission (SEC) has asked the Eighth Circuit Court of Appeals to lift its stay and issue a ruling in Iowa v. SEC, the case challenging the validity of its landmark Climate Disclosure Rules (Rules). At the direction of the court, the SEC filed a status

Continue Reading SEC asks Eighth Circuit Court of Appeals to rule on Climate Rules litigation

The US Court of Appeals for the Eighth Circuit recently granted the Motion to Hold Case in Abeyance (the Motion) in Iowa v. US Securities and Exchange Commission – the case challenging the SEC’s 2024 climate disclosure rules – thereby pausing or delaying the proceedings until further order of the

Continue Reading Eighth Circuit indefinitely pauses SEC climate rule litigation: Key implications for public companies

The Securities and Exchange Commission (SEC)’s March 27, 2025 decision (the Decision) to withdraw the defense of its landmark climate-related disclosure rules adopted in March of 2024 (the Rules) did not formally pause or terminate the ongoing litigation.

On April 4, 2025, a group of 18 intervening states and the

Continue Reading SEC’s climate rule litigation update: Is it actually over?

The US Securities and Exchange Commission (SEC) recently issued a new Compliance and Disclosure Interpretation, Question 103.12 (C&DI), that may significantly impact how public companies engage with their shareholders. Released on February 11, 2025, this C&DI focuses on the eligibility criteria for reporting beneficial ownership on Schedule 13G compared to Schedule

Continue Reading To control or not to control: SEC issues new guidance impacting Schedule 13G filers

On February 11, 2025, Acting US Securities and Exchange Commission (SEC) Chairman and Commissioner Mark Uyeda announced that he has directed the SEC staff to notify the US Court of Appeals for the Eighth Circuit of the changed circumstances surrounding the SEC’s position on the climate disclosure rules. He has

Continue Reading Acting SEC Chair Uyeda will seek pause in climate rules litigation

The US Securities and Exchange Commission (SEC) adopted landmark final rules (Climate Disclosure Rules, or Rules) in March 2024 intended to enhance and standardize climate-related disclosures for publicly listed companies.

The Climate Disclosure Rules required all domestic and foreign publicly traded companies to disclose climate-related risks and mandated certain filers

Continue Reading SEC Climate Disclosure Rules under the Trump Administration