CARB Hosts Third Workshop and Releases Updated Informational Materials Court Grants Motion for SB 261 Injunction

On November 18, 2025, the California Air Resources Board (CARB) hosted a virtual public workshop with stakeholders “to support development of California’s Corporate Greenhouse Gas Reporting Program and the Climate-Related Financial Risk Disclosure Program” established by the Climate Corporate Data Accountability Act (SB 253) and Climate‐Related Financial Risk Act (SB 261), as amended by SB 219. The primary areas of focus during the workshop included:

• Providing information about efforts to refine the preliminary list of covered/reporting entities released on September 24, 2025.
• Presenting updated proposals related to definitions and exemptions under the statutes.
• Reiterating that the scope of the initial regulations CARB plans to present to the board in the first quarter of 2026 is limited to establishing fees to recover program implementation costs, clarifying definitions of key terms in the statutes, and finalizing the first reporting deadline for SB 253.
• Proposing a first-year reporting deadline of August 10, 2026, for SB 253 and clarify the applicable reporting year on the basis of an entity’s fiscal year-end (i.e., fiscal years ending between February 2, 2025, and February 1, 2026).
• Clarifying that CARB will accept greenhouse gas emissions data for 2026 reporting under SB 253, regardless of whether it received limited assurance.

In addition, CARB stated in the workshop slide deck that subsequent rulemaking related to SB 253 will be performed to establish program requirements for 2027 and beyond. Such requirements will include, but will not be limited to, data assurance requirements, further enforcement provisions, recurring reporting deadlines beyond 2026, and reporting templates.

In conjunction with the workshop, CARB released an updated climate-related financial risk disclosure checklist that supersedes the draft checklist posted on September 2, 2025. In addition, CARB posted an updated FAQ document.

For more information about the third virtual workshop, see CARB’s Web site.

On November 18, 2025, the Ninth Circuit Court of Appeals granted the motion for an injunction of SB 261 and denied the motion for an injunction of SB 253. The injunction for SB 261 is in effect while the lawsuits seeking to enjoin the reporting requirements for SB 253 and SB 261 are ongoing.