Consultation on Proposed Rescission of Climate-Related Disclosure Rules

We refer to the Securities and Exchange Commission (SEC)'s request for comment on the proposed rescission of the Final Rules requiring registrants to provide certain climate-related information in their registration statements and annual reports. We appreciate the opportunity to contribute our perspective.

Norges Bank Investment Management (NBIM) is the investment management division of the Norwegian Central Bank that manages the Norwegian Government Pension Fund Global. We work to safeguard and build financial wealth for future generations. As of year-end 2025, we managed over 2 trillion USD in assets, with the United States representing our largest market at 53% of total investments. Within our equity portfolio, 822 billion USD was invested in shares of 1,306 U.S. public companies. We are a minority shareholder in U.S. public companies, with an average equity ownership of 1.2 percent.

As a long-term, diversified financial investor, we rely on companies’ narrative disclosures to add analytical context to financial statements, which informs our investment decisions, shareholder voting and risk management processes. We have an interest in effective disclosure regimes that surface material, investor-relevant information in a consistent and comparable format, without imposing undue cost or duplication on reporting companies. 

NBIM does not recommend outright rescission of the Final Rules. We support the existing framework's materiality standard, which elicits disclosure of climate-related risks when material to a registrant's financial condition. In our view, the Final Rules would add a valuable analytical layer by codifying a structured framework for how climate-related risks, when material, are identified, managed and reflected in company governance, strategy and financial statements. We believe a well-designed framework of this kind can serve the interests of companies and investors alike, and that alternatives to outright rescission exist that would address the Commission's concerns about scope and cost, while preserving a baseline of financially material disclosure.

Our responses to selected consultation questions are provided in Annex 1 to this letter. We thank the Commission for considering our perspectives and remain at your disposal should you wish to discuss these matters further.

Yours sincerely,

Carine Smith Ihenacho
Chief Governance and Compliance Officer                                                 

Snorre Gjerde
Policy Lead