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ARTICLE · 30 JANUARY 2026

CARB Advances Climate Disclosure Rules As Ninth Circuit Appeal Continues

Winston Taylor
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As we previously noted, a legal challenge to California's climate disclosure laws has made its way to the Ninth Circuit Court of Appeals, which stayed enforcement of one of the laws pending appeal.

United StatesEnvironment
Sam Falcon Trimbach
Sam Falcon Trimbach
Madeline Barone
Madeline Barone

As we previously noted, a legal challenge to California's climate disclosure laws has made its way to the Ninth Circuit Court of Appeals, which stayed enforcement of one of the laws pending appeal.1 While the appeal is pending, the California Air Resources Board (CARB) has continued to refine how it plans to operationalize the laws. On December 23, 2025, CARB issued proposed implementing regulations for these laws, together with related staff materials in support of the regulations. The public comment period on the proposed regulations began on December 26, 2025, and runs through February 9, 2026, after which CARB will hold a public hearing on February 26, 2026. Below we discuss several key updates that companies should be aware of, pending resolution of the appeal.

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