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ARTICLE · 11 DECEMBER 2025

Ring In 2026 With A Climate Reporting Reprieve

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On December 1, 2025, the California Air Resources Board (CARB) released an Enforcement Advisory clarifying that it will not enforce SB 261 against covered entities for failing to publish climate-related financial risk reports by the January 1, 2026, statutory deadline

United StatesLitigation, Mediation & Arbitration
Kenneth J. Markowitz
Kenneth J. Markowitz
Stacey H. Mitchell
Stacey H. Mitchell
Andrew Oelz
Andrew Oelz
Brecken Aubrey Petty
Brecken Aubrey Petty
Charles Edward Smith
Charles Edward Smith
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On December 1, 2025, the California Air Resources Board (CARB) released an Enforcement Advisory clarifying that it will not enforce SB 261 against covered entities for failing to publish climate-related financial risk reports by the January 1, 2026, statutory deadline.1

This announcement follows the issuance of an order by the U.S. Court of Appeals for the Ninth Circuit on November 18, 2025, enjoining CARB from enforcing SB 261 pending appeal. CARB has stated that it will provide additional SB 261 guidance, including revised reporting dates, once the legal challenges to the disclosure statute are resolved. Read our prior coverage of the Ninth Circuit's order here.

Simultaneously, CARB opened the public docket for entities tovoluntarilysubmit a link to the climate-related financial risk report posted on the entity's own website. The docket will remain open through July 1, 2026.

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