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.

On February 18, the U.S. Environmental Protection Agency (EPA) issued its final rule repealing the greenhouse gas (GHG) “endangerment finding.” EPA’s leadership has characterized the repeal as a return to a narrower reading of the statute in light of scientific, technological and policy developments since 2009. The move significantly attempts to reshape the federal climate regulatory landscape and promptly drew legal challenges.

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 December 1, 2025, the California Air Resources Board (CARB) released an Enforcement Advisory clarifying that it will not enforce SB 261 against covered entities for failing to publish climate-related financial risk reports by the January 1, 2026, statutory deadline.¹

On November 18, 2025, the U.S. Court of Appeals for the 9th Circuit issued an order enjoining the state of California from enforcing its climate-related financial risk reporting law, SB 261, while the Court hears full arguments on the merits. SB 261 requires covered entities (i.e., companies with over $500 million in annual global revenue who “do business in California”) to publish climate-related financial risk reports on their websites by January 1, 2026.¹

On November 18, 2025, the California Air Resources Board (CARB) will host its third virtual workshop addressing regulations under SB 253 (Climate Corporate Data Accountability Act) and SB 261 (Climate-Related Financial Risk Act). The session follows CARB’s October 2025 decision to delay publishing draft regulations, which originally were slated for board consideration in December 2025.

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.

The California Air Resources Board (CARB) took a significant step forward recently in implementing the state’s climate disclosure laws: SB 253 (the Climate Corporate Data Accountability Act) and SB 261 (the Climate-Related Financial Risk Disclosure law), in each case as amended by SB 219.