California Senate Bill 261 (the Climate-Related Financial Risk Act; SB 261) requires certain businesses to submit biennial disclosures of climate-related financial risks, as well as the measures they have implemented to reduce such risks. U.S. organized entities “doing business in California” with “revenues” exceeding $500 million in the prior year are subject to this requirement. A similar law, California Senate Bill 253 (the Climate Corporate Data Accountability Act; SB 253), requires regulated companies to annually disclose their emissions beginning in June 2026.

The initial set of disclosures required under SB 261 are due to be posted on a regulated company’s website by Jan. 1, 2026, and submitted to the California Air Resource Board (CARB) by July 1, 2026. While SB 261 is currently being challenged in court, these deadlines have not been extended.

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Photo of Michael P. Canavan Michael P. Canavan

Michael P. Canavan is a member of the Environmental Practice at Greenberg Traurig. He focuses his practice on providing counsel on environmental issues associated with real estate and corporate transactions. Michael represents private equity firms, real estate opportunity funds, commercial and residential real…

Michael P. Canavan is a member of the Environmental Practice at Greenberg Traurig. He focuses his practice on providing counsel on environmental issues associated with real estate and corporate transactions. Michael represents private equity firms, real estate opportunity funds, commercial and residential real estate developers, and companies in highly-regulated industries in connection with environmental due diligence, contractual allocation of associated risks and liabilities, insurance procurement, and regulatory compliance. Clients rely on Michael for his ability to quickly identify and evaluate environmental issues arising from the acquisition, financing, ownership, and sale of real property, and he draws on his experience having assisted with hundreds of real estate transactions in the majority of U.S. states, the United Kingdom, the European Union, and Japan.

Photo of Travis Coon Travis Coon

Travis Coon is a member of the Environmental Practice in Greenberg Traurig’s Philadelphia office. Travis’ practice focuses on environmental issues associated with corporate and real estate transactions. He also represents and counsels clients in environmental regulation matters.

Photo of Madeline Orlando Madeline Orlando

Madeline Orlando is a member of the Litigation Practice in Greenberg Traurig’s Sacramento office. She represents clients in environmental matters, focusing on regulatory issues, hazardous waste litigation, and state regulations including California’s Cleaning Product Right to Know Act.