California Mandatory Climate Disclosure Laws Move Forward With Little Concession

As discussed in our prior legal update available here, in 2023, California enacted two laws that mandate certain climate-related emissions disclosures and financial risk reporting for thousands of public and private companies "doing business" within the state. See Senate Bill 253, the Climate Corporate Data Accountability Act ("SB 253"); Senate Bill 261, the Greenhouse gases: climate-related financial risk ("SB 261"). Together, the legislation is referred to as the Climate Accountability Package. California took the lead – among states and the federal government – to require emissions disclosures without regard to materiality of what is known as Scope 3 disclosures.¹

While SB 253 and 261 are currently being challenged in court, implementation of the laws have not been stayed. As such, companies subject to either or both SB 253 and SB 261 have had to take the necessary steps to ready themselves for compliance with the laws absent regulatory guidance from the