1 Please also refer to Autodesk's comment on question 13 in the FASB Invitation to Comment ("ITC") Agenda Consultation We strongly support the Commission's effort to improve and standardize climate-related disclosures in public financial filings. We have been working toward this goal for several years, both individually and as a part of advocacy organizations, and believe greater transparency is an increasing priority for our shareholders and stakeholders. Specific to Greenhouse Gas Emissions ("GHG") reporting, we firmly believe in the value of collecting the data, measuring our progress, and reporting on the attainment of our goals. Measuring our footprint enables us to manage our climate impact, thereby providing investors and other stakeholders with an accurate view of climate-related risks and opportunities within our business. Because of the importance of this data to our investors, we have received limited assurance for most of our emissions data for several years and received limited assurance for our entire fiscal year 2022 emissions inventory. A particular challenge has been the number of competing disclosure frame- works that have arisen over time, including the Global Reporting Initiative, the Carbon Disclosure Project (“CDP”), the Value Reporting Foundation, and the Task Force on Climate-Related Financial Disclosure (“TCFD”). Identifying standards for our climate-related financial disclosures has been a shifting target, so we see great value in the Commission standardizing on a single framework in its proposal. We believe that the TCFD framework provides a reasonable balance between improved disclosure and compliance costs. We have been working for some time to implement TCFD and are, therefore, highly supportive of the Commission’s selection of this framework as the basis for its climate disclosure requirements. While we support the Commission’s objective and approach, we have carefully considered the Commission’s proposal. To achieve a more reasonable balance between the cost of compliance and the benefit to investors, we suggest the Commission consider the suggestions in the remainder of this letter in two areas: 1) proposed financial disclosures and 2) GHG disclosures. Proposed Financial Disclosures Rather than the proposed new audited footnote disclosure within the financial statements, we believe the Commission should direct the Financial Accounting Standards Board (“FASB”) to add a project to their agenda that would focus on proposing disclosure requirements that enhance existing U.S. Generally Accept- ed Accounting Principles ("U.S. GAAP") for climate-related events, transactions, transition activities, and estimates in the audited financial statement footnotes. 1 With respect to a company’s climate-related financial impact, expenditures, estimates, and assumptions, we also agree with the Commission’s suggestion in Question 89 that disclosure of such information could reasonably be made outside the financial statements and within the proposed separately captioned item in the specified forms. We also suggest it be done on a prospective basis. --.:I AUTODESK in 2021 regarding the treatment of ESG-related transactions available at https://www.fasb.org/document/blob?file- Name=AGENDACONSULT.ITC.078.AUTODESK%20INC.%20STEPHEN%20HOPE,O.pdf