At its February 26, 2026 meeting, the California Air Resources Board (“CARB”) approved a key step in implementing California’s landmark climate disclosure laws. CARB adopted the long-awaited California Corporate Greenhouse Gas Reporting and Climate Related Financial Risk Disclosure Initial Regulation (“Initial Regulation”) implementing the Climate Corporate Data Accountability Act (SB 253) and the Climate-Related Financial Risk Act (SB 261). The Initial Regulation establishes the administration and implementation fee structure for SB 253 and SB 261 and sets the first emissions reporting deadline under SB 253: August 10, 2026. Notably, compliance with SB 261 remains voluntary after the U.S. Court of Appeals for the Ninth Circuit enjoined enforcement of that law.

Our previous, in-depth analysis of these two laws can be found here. In general, SB 253 and SB 261 require large companies doing business in California to disclose climate-related information, including Scope 1, 2, and 3 greenhouse gas (“GHG”) emissions and climate-related financial risks. SB 253 applies to companies with more than $1 billion in annual revenue, while SB 261 applies to companies with more than $500 million in annual revenue. As clarified in the Initial Regulation, these revenue thresholds are tied to entities’ gross receipts as reported to the California Franchise Tax Board.