In November, we shared the news that the California Air Resources Board (CARB) released updated guidance on the climate risk disclosure requirements under SB 261 and SB 253. You may recall that the Ninth Circuit Court of Appeals issued an injunction that temporarily halted enforcement of SB 261. It should be noted that this applies only to SB 261. SB 253 is not affected and remains in force.
More recently, CARB has opened a public docket for entities that wish to voluntarily submit Climate-Related Financial Risk Reports under SB 261.
Oral argument is scheduled for January 9, 2026, which falls after the original January 1, 2026 reporting deadline. Therefore, CARB will not enforce the reporting deadline and submitting reports is now optional until the appeal is resolved.
For more details, entities can access the public docket, review CARB’s enforcement advisory, and visit the Corporate GHG Reporting and Climate Risk Disclosure Programs webpage: https://ww2.arb.ca.gov/our-work/programs/california-corporate-greenhouse-gas-ghg-reporting-and-climate-related-financial.
Feedback can also be submitted to climatedisclosure@arb.ca.gov.
What does this mean for your organization?
— No legal obligations beginning January 1st: the requirement is formally on hold.
— CARB is opening the reporting registry this month, but participation is voluntary for now.
— The timeline from the January 9th hearing remains uncertain. A ruling could take days or even months.
— No new compliance date will be set until that ruling is issued.
— There’s no indication of any changes to the law beyond timing. Compliance requirements could remain the same or could evolve.
For many companies, the pause on SB 261 means more time to prepare, refine internal processes, and strengthen the quality of disclosures.
Pure Strategies Can Help!
To understand what this means for your reporting plans, or if you want to stay ahead – despite the shifting timelines, our team can help. Schedule time with one of our sustainability consulting experts who can help navigate next steps for your business.
