California’s climate disclosure laws continue to present novel challenges and twists and turns to regulated businesses, and the past month is no exception. Since our last blog post on this topic, there have been significant developments regarding the implementation of SB 261 and SB 253. On November 18, 2025, the Ninth Circuit Court of Appeals enjoined the California Air Resources Board (CARB) from enforcing SB 261, which requires companies to disclose climate-related financial risks. Importantly, the injunction was issued prior to the January 1 deadline for companies to publish their climate-related financial risk report pursuant to SB 261. On December 1, 2025, CARB issued an Enforcement Advisory confirming it would not enforce against companies for failure to post a climate-related financial risk report on January 1, 2026. Then, on December 9, 2025, CARB posted proposed regulations applicable to SB 253 and SB 261. Further details and considerations are discussed in this blog post.