In March 2022, the SEC issued a proposal (Proposal) for rules (Rules) that would require public companies to disclose certain climate-related information. In a recent Sullivan & Cromwell program, partners Catherine M. Clarkin, Robert W. Downes, Sarah P. Payne and Marc Treviño, as well as senior policy advisor and counsel – and former SEC Chair – Jay Clayton, analyzed the Proposal’s content and the possible impact of the Rules on both public companies and private fund managers. This second article in our two-part series outlines the broad implications of the Proposal; key challenges and timing; and the anticipated pushback. The first article reviewed the five key elements of the Proposal. See “Core Features of the SEC’s Proposed ESG Rules and the Ethos Driving Its Release” (Jul. 26, 2022).