CARB - Enforcement Advisory

On December 1, 2025, the California Air Resources Board (CARB) released anenforcement advisory, announcing that it will not enforceSenate Bill (SB) 261, which requires certain entities that do business in California and have $500 million or more in annual revenue to publish a biennial climate-related financial risk report. The announcement was made after, and in response to, the Ninth Circuit Court of Appeals granted an injunction, pending appeal, against the enforcement of SB 261.¹ Argument for the appeal is set for January 9, 2026, which is after the original SB 261 reporting deadline of January 1, 2026. In the enforcement advisory, CARB confirmed that it would provide further information, including a possible alternative reporting deadline, at a later date. In the interim, companies may voluntarily submit their respective climate-related financial risk reports through CARB'spublic docket, which went live on December 1, 2025.

For more information on SB 261, please see ourinitialCalifornia climate disclosure advisory and ouradvisory on CARB's recently published FAQs.

Footnote

1 Chamber of Commerce of the United States et al. v. Sanchez et al., No. 25-5327 (9th Cir. 2025).

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