DOD, GSA, and NASA Propose Climate Disclosures for Large Federal Contractors

On November 14, 2022, the Department of Defense (DoD), General Services Administration (GSA), and National Aeronautics and Space Administration (NASA) issued a proposed rule amending the Federal Acquisition Regulation (FAR) to implement a requirement to ensure that certain Federal contractors disclose their greenhouse gas emissions and climate-related financial risk and set science-based targets to reduce their greenhouse gas emissions.

This rule proposes to separate “major Federal suppliers” into two categories:

  1. "Significant contractors," who received between $7.5 and $50 million in Federal contract obligations in the previous year, and
  2. "Major contractors," who received more than $50 million in Federal contract obligations in the previous year.

Per this proposed rule, both significant contractors and major contractors would be subject to annual Scope 1 and Scope 2 GHG emissions disclosure requirements. Major contractors would also be subject to the annual climate disclosure, which includes disclosure of Scope 3 GHG emissions, and science-based target requirements.

On December 23, 2022, DoD, GAS, and NASA extended the comment period for the proposed rule until February 13, 2023.