The entity that manages roughly $2 trillion in global assets just told the SEC its plan to gut climate reporting is a bad idea. Norway’s Government Pension Fund Global, the world’s largest sovereign wealth fund, has formally opposed the Securities and Exchange Commission’s proposal to rescind climate-related disclosure rules for public companies.
Norges Bank Investment Management (NBIM), which oversees the fund’s sprawling portfolio, submitted comments arguing that climate risks carry significant financial relevance and that reliable reporting on those risks is essential for investors making capital allocation decisions. The fund didn’t just say “keep the rules.” It offered a middle path: phase in implementation rather than ripping up the rulebook entirely.
What the SEC proposed and who’s fighting it
On May 29, the SEC proposed to fully rescind climate disclosure rules it had finalized just over two years earlier, in March 2024. The commission cited concerns about its statutory authority to impose such requirements and pointed to the compliance costs companies would face.
The public comment period for the proposal closed on August 3, giving institutional investors and other stakeholders a window to weigh in. Norway’s sovereign fund used that window to make its position clear.
NBIM isn’t alone in pushing back. Sweden’s AP7 pension fund, California’s CalSTRS, and several New York pension funds have also challenged the SEC’s rationale for rescission. The collective argument from these institutional heavyweights boils down to a simple premise: climate risk is financial risk, and stripping away disclosure requirements leaves investors flying blind.
This isn’t NBIM’s first time advocating for climate transparency at the SEC. Back in 2022, the fund submitted comments supporting standardized climate disclosures during the initial rulemaking process.
Why a $2 trillion fund cares about disclosure rules
The fund has backed this concern with action. In 2024, NBIM engaged with 424 companies specifically on climate change topics. It has set expectations for portfolio companies to align with the Paris Agreement and achieve net-zero emissions by 2050, targets outlined in its 2030 Climate Action Plan.
NBIM’s argument to the SEC wasn’t that compliance costs don’t matter. The fund acknowledged the burden on companies but suggested that a phased implementation schedule would be a more constructive solution than wholesale elimination.