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ARTICLE · 13 OCTOBER 2025

California Climate Disclosure Rules Come Into Focus As 2026 Deadlines Near

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Recently, in Chamber of Commerce of the United States of America v. California Air Resources Board,1 the United States District Court for the Central District of California denied the U.S.

United StatesEnvironment
Mark D. Perlow
Mark D. Perlow
Brooke Skartvedt Guven
Brooke Skartvedt Guven
Patrick K. McCarthy
Patrick K. McCarthy

Key Takeaways

  • The California Climate Disclosure Laws will require U.S. companies doing business in California to prepare biennial climate-related financial risk reports and to make annual disclosures of their greenhouse gas emissions, subject to certain revenue and other thresholds.
  • The California State Air Resources Board ("CARB") has not yet proposed or adopted implementing regulations for the California Climate Disclosure Laws.
  • CARB has indicated that it intends to follow the definition of "doing business in California" under the California Revenue and Tax Code § 23101.
  • CARB's signaled definitions could capture a significant portion of fund managers that have business operations in California beyond certain low financial thresholds, but there is a possibility that these definitions could exclude some or many investment funds.

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