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 New York Department of Environmental Conservation (NYDEC) finalized regulations for its greenhouse gas (GHG) emissions reporting program under the Climate Leadership and Community Protection Act (CLCPA).¹ These rules establish mandatory annual GHG reporting requirements for certain facilities and suppliers beginning June 1, 2027, with earlier compliance milestones for Large Emission Sources and anaerobic digestion, liquid waste storage and certain solid waste landfill operators taking effect in late 2026. We previously wrote about the draft regulations here.

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.

Akin is proud to be a Platinum Sponsor of Infocast’s Projects & Money Summit taking place January 12–14, 2026 in New Orleans.