On September 24, 2025, the California Air Resources Board (CARB) published a list of entities it believes may be subject to the state’s climate disclosure laws, Senate Bill (SB) 253 and SB 261, which require companies “doing business in California” and meeting certain revenue thresholds to disclose their greenhouse gas emissions (SB 253) and climate-related financial risks (SB 261). Both laws require disclosing entities to pay CARB annual implementation fees. The preliminary list is “intended to support development of the fee regulation” according to CARB‘s announcement. However, the list is generating surprise and confusion among the regulated (and non-regulated) community, some of whom expected to find themselves on the list, and others who did not. Adding to the confusion, CARB made clear that the list includes entities that, at least under its initial staff concepts, would be exempt from the laws; the list also appears to include insurance companies that may be statutorily exempt from SB 261.