New Updates To California's Climate Disclosure Laws

On December 9, 2025, the California Air Resources Board (CARB) issued draft regulations for implementing California's climate disclosure laws, SB 253 (the Climate Corporate Data Accountability Act) and SB 261 (the Climate‑Related Financial Risk Act). On December 23, 2025, CARB made some minor updates to the proposed regulation text.

The proposed regulation is limited to establishing a fee structure for SB 253 and SB 261 and the first year reporting deadline of August 10, 2026 for SB 253, but also defines key terms necessary for both SB 253 and SB 261, such as "doing business in California" and "revenue," to clearly determine which entities will be covered by these programs. For a more in depth review of California's climate disclosure laws and their compliance requirements, please refer to our prior alerts.