The revitalized Caremark doctrine is likely to be employed by shareholder-plaintiffs' law firms as the basis for complaints that boards and managers failed to oversee so-called "mission-critical" aspects of their business that generate climate-related risk. In the past, Caremark claims were almost exclusively applied to address legal, regulatory and accounting compliance issues regarding a company's "business performance." 7 But the promulgation of new environmental disclosure requirements will likely spur new Caremark claims if and when a board fails to exercise proper oversight with respect to climate-related risks or to consider proper mitigating steps. 8