Climate Finance Policy Engagement Analysis
Climate Lobbying Overview: The Council of Institutional Investors (CII) appears to be positively engaged on climate-related finance policy, generally supporting regulated corporate climate disclosure and advocating for shareholder rights. CII does not appear to have engaged on real economy climate policy or taken a position on energy, industry, or land transitions.
Top-Line Messaging on Climate-Related Finance Policy: CII does not appear to have taken clear positions on the need for reform to achieve a sustainable financial system, the need for action to combat climate change, or the need for government policy on climate finance.
Position on Regulated Corporate Climate Disclosure: CII appears generally supportive of regulated corporate climate disclosure, and on its website, accessed in May 2024, has listed mandatory climate risk disclosure as one of its 2024 advocacy priorities.When the SEC released its proposed climate disclosure framework in 2022, CII was generally supportive of the rules, asserting that the benefits of mandating Scope 3 emissions outweigh the costs, but advocating for the 1% threshold for financial metrics disclosure to be replaced by a materiality threshold. In a November 2023 article CII Executive Director Amy Borrus reiterated CII’s support for the rules and the SEC’s role in crafting them. In March 2024 CII tweeted in support of the SEC’s adoption of final disclosure rules.
Position on Incorporating Climate Factors Into Investor Duties: CII was a strong opponent of Trump-era regulations that sought to limit shareholder rights and ESG investing, asserting in 2020 comments that the regulations were driven by “lobbyists for corporate executives” that object to environmental or social shareholder proposals. In May 2021, CII supported the Biden Administration’s decision not to enforce the Trump-era shareholder and ESG investing rules, but in comments on regulation proposed by the Department of Labor to reverse its Trump-era rules CII asked that some language guiding ESG considerations be made less stringent. In August 2022, CII supported an SEC proposal that sought to strengthen shareholder rights.