FAR Council Delivers Last-Minute Holiday Gift by Extending the Comment Period on Proposed Rule Imposing Mandatory Climate Disclosures for Federal Contractors
Client Alert | 1 min read | 12.23.22
On December 23, 2022, the Department of Defense (“DoD”), General Services Administration (“GSA”), and National Aeronautics and Space Administration (“NASA”) extended the comment period on the proposed rule, “Disclosure of Greenhouse Gas Emissions and Climate-Related Financial Risk,” from January 13, 2023 to February 13, 2023. As we summarized previously, the proposed rule would, if finalized, require thousands of federal contractors to inventory and publicly disclose their Scope 1 and Scope 2 greenhouse gas (“GHG”) emissions, while further requiring “major” contractors to also establish and validate GHG emission-reduction targets tailored to the goals of the Paris Agreement.
The 30-day extension should be a welcome surprise to a wide range of contractors still attempting to unwrap the impact of this largely unprecedented proposal. Crowell’s team stands ready to assist in evaluating the implications and identifying issues worthy of comment.
Insights
Client Alert | 6 min read | 07.17.25
On 11 July 2025, the European Commission published the final version of its Code of Practice for General-Purpose Artificial Intelligence (GPAI). This Code is meant to serve as a tool for GPAI model providers, helping them to comply with the transparency, copyright and security provisions governing general-purpose AI models as set out in the AI Act (arts. 53 and 55), which will become applicable on 2 August 2025. Adherence to the Code is on a voluntary basis.
Client Alert | 3 min read | 07.17.25
(Not the Funniest) Weekend Update: Recap of Recent Developments in the EU-US Tariff Dispute
Client Alert | 5 min read | 07.16.25
Client Alert | 8 min read | 07.16.25