focus on deciding the merits” of the consolidated case. Finally, the SEC noted that the stay of the Final Rules is limited to the rules challenged in the litigation pending in the Eighth Circuit and does not stay any other rules or SEC guidance. Therefore, the 2010 SECGuidance Regarding Disclosure Related to Climate Changecontinues to be relevant and applicable.What to Do Now?The SEC stayed the Final Rules pending the completion of the judicial review of the consolidated petitions in the Eighth Circuit. Companies should continue to consider existing disclosure obligations related to climate-related matters. The stay is anticipated to impact companies differently based on specific sustainability drivers and compliance obligations. Many companies may opt to continue preparation for climate-related risk, emissions, or financial disclosures despite the current challenges to the Final Rules and the SEC stay.[1]The Enhancement and Standardization of Climate-Related Disclosure for Investors, 89 Fed. Reg. 21,688 (Mar. 28, 2024).