Speaking Sustainability

On March 23, 2026, the California Air Resources Board (CARB) held a public workshop on implementation of the Corporate Climate Data Accountability Act (SB 253), as companies prepare to comply with initial greenhouse gas (GHG) reporting requirements later this year. The workshop followed CARB’s February 2026 adoption of initial regulations under SB 253 and SB 261, which we discussed here, and focused largely on potential future rulemakings, particularly with respect to Scope 3 emissions, GHG accounting methodologies, assurance and organizational boundary setting.

The California Air Resources Board (CARB) recently finalized a narrowly crafted, initial set of implementing regulations (Regulations) for California’s climate‑reporting statutes (i.e., SB 253 greenhouse gas (GHG) emissions reporting) and SB 261 (climate‑related financial risk disclosures).¹ As adopted, the Regulations largely mirror the proposal issued in December 2025, without material changes. The Regulations provide a limited set of foundational compliance mechanics, but defer many consequential issues to future rulemaking initiatives, particularly in relation to how Scope 3 GHG emissions are to be reported under SB 253.

In a presidential memorandum issued January 7, President Trump announced the United States will begin executive proceedings to withdraw from a historic number of international organizations, conventions and treaties, including the United Nations Framework Convention on Climate Change and others aimed at environmental protection and climate action.

On January 9, 2026, the Ninth Circuit heard oral argument in an appeal challenging California’s climate reporting laws: SB 253 (emissions disclosure) and SB 261 (climate‑related financial risk reporting).¹ The court previously stayed enforcement of SB 261 pending appeal, leaving SB 253 in place for now. We have covered the procedural background leading to oral argument here.

The 30th United Nations Climate Change Conference (COP30) ended on November 22, 2025. Among other things, the package of decisions reflected in the Belém Political Package brings renewed focus on scaling up climate finance and accelerating implementation of the Paris Agreement. The event sharpened focus on implementation and finance rather than binding global commitments. Key issues emerging out of COP30 include:

On November 18, the United States Court of Appeals for the Ninth Circuit granted a partial injunction blocking enforcement of California’s climate-related financial risk disclosure law (SB 261). Inaugural reports under SB 261 were intended to be published by reporting entities by January 1, 2026. Akin wrote on the subject in full detail here.

On December 9, 2025, the California Air Resources Board (CARB) announced that it will convene a public hearing on February 26, 2026, to consider approving the adoption of regulations governing California’s climate-related disclosure statutes: SB 253 and SB 261.[1] CARB also published the proposed regulatory text, which we explore below.

The California Air Resources Board (CARB) recently added a notice to its webpage indicating that it will further delay the issuance final regulations for California’s climate-related reporting statutes (Senate Bills 253 and 261), likely until the first quarter of 2026.

Despite litigation challenges and regulatory delays, deadlines are not shifting for reporting under California’s Climate Disclosure laws. Most recently, California Air Resources Board (CARB) delayed publishing draft regulations for SB 253 and SB 261, citing extensive public comments and ongoing input on covered entities. Despite the fact that CARB expects to publish an updated timeline for final regulations in early 2026, inaugural reporting under SB 261 is due by January 1, 2026.