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ARTICLE · 15 SEPTEMBER 2025

CARB Publishes Draft Guidance For Initial Reports Under California's Climate‐Related Financial Risk Act (S.B. 261)

Beveridge & Diamond, P.C.
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On September 2, the California Air Resources Board (CARB) published its long-awaited draft guidance on compliance with California's Climate‐Related Financial Risk Act...

United StatesEnvironment
Eric L. Christensen
Eric L. Christensen
Brook Detterman
Brook Detterman
Claire Schachter
Claire Schachter
Kirstin Gruver
Kirstin Gruver

On September 2, the California Air Resources Board (CARB) published its long-awaited draft guidance on compliance with California's Climate‐Related Financial Risk Act (S.B. 261) (codified in Health & Safety Code Section 38533). Companies subject to S.B. 261 must publish their initial climate-related financial risk report on their website by January 1, 2026, and post the location of the link to the report on CARB's public docket.

S.B. 261 requires companies to disclose climate-related financial risk and the measures adopted to reduce and adapt to climate-related financial risk in biennial reports prepared in accordance with certain frameworks; however, the law does not describe the specific information companies must include in those reports. Subject companies have thus been eagerly awaiting guidance from CARB on what information they must include in their initial reports. CARB previously published a set of FAQs addressing certain aspects of S.B. 261 and its sister

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