A proposed rule issued last week by the Biden Administration would require all contractors with over $50 million per year in government business to disclose a wide range of greenhouse gas emission information.  Even companies with just $7.5 million in government contracts would have to disclose at least some information.  Although the rule is only in the proposed stage, GSA has already added the requirement to at least one draft RFP.  GSA contractors can expect to see the requirement in all RFP’s, or as a contract modification, once there is a final standard.  Larger companies would have to track and report on so-called Scope 1, Scope 2, and relevant Scope 3 categories of emissions, disclose climate-related financial risks, and set science-based emissions reduction targets.  The standards leverage widely-adopted third party standards and systems, including the CDP environmental reporting system, the Task Force on Climate-Related Financial Disclosures (TCFD) Recommendations, and the Science Based Targets Initiative (SBTi) criteria.  The proposed rule for contractors is similar in nature to an earlier rule proposed by the SEC.  The costs for companies to comply could be substantial.  Systems would have to be created to track and report relevant information, plans created on how to reduce a company’s emissions, and people hired to oversee such actions.  Contractors will inevitably have to increase their prices to government agencies to offset the increased costs, making the initiative doubly expensive for contractors – first as a company having to adopt the new standards, and again as taxpayers contributing to the increased cost of government acquisition.  Companies should carefully review the rule and ensure that they understand what may be required of them.  While comments are an acknowledged best practice, it is quite likely that the proposed rule will move forward.  As such, being prepared now gives companies a longer runway to adapt.