Some companies that do business in California are facing rapidly approaching compliance deadlines under California’s climate disclosure laws, SB 253 and SB 261, the first of which will occur on Jan. 1, 2026. On Nov. 10, a number of plaintiffs, led by the U.S. Chamber of Commerce, filed an Emergency Application for Injunction Pending Appeal at the U.S. Supreme Court after failing to obtain similar relief from either the District Court or Ninth Circuit Court of Appeals (which set oral argument for Jan. 9, over a week after the SB 261 compliance deadline). However, the outcome of this litigation remains unclear and covered entities may wish to continue preparing under the assumption that implementation will not be enjoined.
New California Climate Disclosure Law Deadlines Are Rapidly Approaching: Compliance Considerations for Companies