California Provides Additional Guidance On Mandatory Climate Disclosures

On May 29, 2025, the California Air Resources Board delivered a presentation that provided additional details concerning the soon-to-be implemented mandatory climate disclosures. Perhaps most significantly, the California regulator gave additional guidance on which companies will be subject to the law. Specifically, the California Air Resources Board stated that they planned to rely upon the tax code's interpretation of "doing business in California" to determine whether a company needed to make the regulatory disclosure. So, in practical terms, this means that sales in California of $735,019 or more, or owning real property in California worth more than $73,502 or paying employees in California more than $73,502, would constitute "doing business in California" for purposes of complying with the mandatory climate disclosure (subject to the other statutory requirements--e.g., meeting the revenue threshold of either $1 billion or $500 million, depending upon the type