As the January 1, 2026, deadline to make the first required disclosure under California’s landmark climate laws approaches, the California Air Resources Board (CARB) has announced that it will host another virtual public workshop on August 21 to discuss its ongoing efforts to develop regulations implementing California Senate Bills (SBs) 253 and 261. SB 253 (updated by SB 219) and SB 261, which are now codified in Sections 38532 and 38533 of the California Health and Safety Code, mandate certain entities to disclose climate-related financial risks by January 1, 2026, and greenhouse gas (GHG) emissions by a date to be determined later in 2026. As CARB announced in its May 29, 2025, workshop, the agency does not intend to issue draft regulations until the end of the year, despite SB 219’s July 1, 2025, deadline. This has left many companies potentially affected by those regulations in the dark regarding whether they will be required to make disclosures. CARB’s August 21 workshop may finally provide clarity on some of the key applicability questions that remain unanswered as these 2026 disclosure deadlines loom.

Based on the workshop announcement distributed to interested parties on August 7, CARB intends to resolve some of the thorniest issues presented by SBs 253 and 261 at its August 21 workshop, namely, what it means to “do business in California,” how revenue will be defined for purposes of triggering disclosure requirements, and considerations related to intra-corporate relationships. CARB indicated the workshop will also present a draft framework for fee regulation, provide an update on the regulatory timeline, and discuss assurance requirements for GHG reporting and the phase-in of Scope 3 emissions reporting, among other items. CARB will accept feedback from the public during the workshop and will open a docket for three weeks following the workshop to accept written comments.

CARB’s virtual workshop is scheduled for August 21 from 9:30 a.m. to 12:30 p.m. PT.

Photo of Shawn Zovod Shawn Zovod

Shawn practices environmental and natural resources law and strategy. She specializes in Clean Water Act (CWA), Porter-Cologne Water Quality Control Act, Endangered Species Act (ESA), Marine Mammal Protection Act (MMPA), and National Historic Preservation Act (NHPA) permitting, as well as the preparation of…

Shawn practices environmental and natural resources law and strategy. She specializes in Clean Water Act (CWA), Porter-Cologne Water Quality Control Act, Endangered Species Act (ESA), Marine Mammal Protection Act (MMPA), and National Historic Preservation Act (NHPA) permitting, as well as the preparation of environmental documents under the National Environmental Policy Act (NEPA) and the California Environmental Quality Act (CEQA).

Photo of Jason Langford Jason Langford

Jason is an associate in the firm’s Corporate practice. He focuses his practice primarily on helping domestic and foreign issuers raise capital while complying with the disclosure obligations and reporting requirements under the Securities Act of 1933 and Securities Exchange Act of 1934…

Jason is an associate in the firm’s Corporate practice. He focuses his practice primarily on helping domestic and foreign issuers raise capital while complying with the disclosure obligations and reporting requirements under the Securities Act of 1933 and Securities Exchange Act of 1934, as well as securities exchange requirements and listing standards. In addition, he assists companies with corporate governance and affiliated entity management, supports merger and acquisition transactions, and assists with general corporate and compliance matters.