On Nov. 14, the Federal Acquisition Regulatory Council issued a proposed rule to amend the Federal Acquisition Regulation to require certain federal contractors to disclose their greenhouse gas emissions and set GHG emission reduction targets.

Under the proposed rule, federal contractors who qualify as significant contractors, (those receiving between $7.5 million and $50 million in federal contracting obligations in the prior fiscal year) would be required to inventory their annual GHG emissions and disclose this information to the federal government.

Major contractors (receiving over $50 million in contracting obligations) would also be required to make publicly available CDP climate disclosures and set targets for reducing GHG emissions.

Contractors that fail to comply with these requirements would be deemed nonresponsible and ineligible for federal awards.

Comments on the proposed rule are due by Jan. 13, 2023, and may be submitted via regulations.gov. Please reach out to Michael Altman at [email protected] with any questions or comments on the potential impact of this proposal.