Prof. Jill E. Fisch has authored an excellent piece about sustainability disclosure. Her proposal to mandate a new Sustainability Disclosure and Analysis section of SEC filings is an interesting idea for improving the disclosures that investors currently receive regarding such important matters as climate change, human capital, and a range of other issues. She also proposes that company management certify as to the accuracy of these disclosures, another step toward improved disclosure. But it is likely the case that without significant tweaks, her suggestion would not improve the consistency and comparability of disclosures. This is because her proposal is principles-based, that is, issuers would decide for themselves the three most significant sustainability issues and then decide what to disclose about these issues.