Under international standards such as the UN Guiding Principles and the OECD Guidelines, companies are expected to conduct human rights and environmental due diligence to identify, assess, mitigate and remediate any adverse human rights or environmental impacts that they cause, contribute to or are otherwise linked to. A failure to do so can expose a
Unraveling California’s Web of Climate Disclosure Laws, Part 2: Climate Corporate Data Accountability Act (SB 253)
California is forging a path for climate disclosure with its series of related legal frameworks requiring covered entities to disclose climate-related information, supporting documentation for certain net zero claims and financial risk frameworks.
In October 2023, California became the first state to enact such broad climate disclosure legislation, with the passage of the:
- Climate-Related Financial Risk Act (SB 261),
- Climate Corporate Data Accountability Act (SB 253), and
- California’s Voluntary Carbon Market Disclosures Act (AB 1305).
Entities covered by these three programs generally include those that do business in the state of California and either (1) make certain climate related claims about the business, its products, etc.; (2) market and/or purchase certain voluntary carbon offsets; and/or (3) meet certain monetary thresholds (for purposes of SB 253 and SB 261).
With compliance deadlines already in place or approaching quickly, implementation has been challenging for industry. The California Air Resources Board (CARB) is responsible for promulgating regulations associated with the three statutory programs, but has yet to do so. AB 1305 has already gone into effect, with its first deadline occurring as of January 1, 2025. SB 253 and SB 261 have deadlines starting in 2026. Like AB 1305, SB 261’s climate-related financial risk disclosure requirement does not depend on CARB completing its rulemaking prior to when the first reports are due on January 1, 2026. However, SB 253 differs from the other two in that no reporting obligations are imposed without CARB’s adoption of implementing regulations. Regulated entities needs to be prepared to comply while remaining flexible given pending publication of regulations in December.
To assist, this three part series provides a high-level guide on the three programs, including the applicability, the program’s coverage, steps for compliance, timing and other miscellaneous information based on current regulatory guidance. Here we focus on disclosure under California’s Climate Corporate Data Accountability Act (SB 253), which has an anticipated reporting deadline of July 30, 2026 (pending promulgation of implementing regulations).
Unraveling California’s Web of Climate Disclosure Laws, Part 1: Climate-Related Financial Risk Act (SB 261)
California is forging a path for climate disclosure with its series of related legal frameworks requiring covered entities to disclose climate-related information, supporting documentation for certain net zero claims and financial risk frameworks.
In October 2023, California became the first state to enact such broad climate disclosure legislation, with the passage of the:
- Climate-Related Financial Risk Act (SB 261),
- Climate Corporate Data Accountability Act (SB 253), and
- California’s Voluntary Carbon Market Disclosures Act (AB 1305).
Entities covered by these three programs generally include those that do business in the state of California and either (1) make certain climate related claims about the business, its products, etc.; (2) market and/or purchase certain voluntary carbon offsets; and/or (3) meet certain monetary thresholds (for purposes of SB 253 and SB 261).
With compliance deadlines already in place or approaching quickly, implementation has been challenging for industry. The California Air Resources Board (CARB) is responsible for promulgating regulations associated with the three statutory programs, but has yet to do so. AB 1305 has already gone into effect, with its first deadline occurring as of January 1, 2025. SB 253 and SB 261 have deadlines starting in 2026. Like AB 1305, SB 261’s climate-related financial risk disclosure requirement does not depend on CARB completing its rulemaking prior to when the first reports are due on January 1, 2026. However, SB 253 differs from the other two in that no reporting obligations are imposed without CARB’s adoption of implementing regulations. Regulated entities needs to be prepared to comply while remaining flexible given pending publication of regulations in December.
To assist, this three part series provides a high-level guide on the three programs, including the applicability, the program’s coverage, steps for compliance, timing and other miscellaneous information based on current regulatory guidance. Here we focus on disclosure under California’s Climate-Related Financial Risks Act, SB 261, which has an initial compliance deadline of January 1, 2026.
When EPA Comes Knocking: Guidance on Environmental Enforcement
Originally published in The Advocate, the magazine of the Idaho State Bar (October 2025).
EPA enforcement activity remains an ongoing concern for regulated entities, even amid shifting political priorities. In this article, Stoel Rives attorneys outline how the EPA exercises its inspection and enforcement authority and what businesses can do to prepare.
They
California Enacts New Electric Transmission Financing Programs and Adds to Its Wildfire Fund
The state of California has adopted SB 254, a comprehensive energy bill designed to reform the state’s utility regulation and development of clean energy infrastructure, with the goal of reducing electricity costs, improving wildfire safety, and accelerating the state’s transition to clean energy.
David Keeling Confirmed as OSHA Chief: A New Era for Cooperation and Enhanced Occupational Safety?
Seyfarth Synopsis: David Keeling’s confirmation as OSHA Chief could give regulatory and enforcement direction to OSHA when federal government funding is restored, likely moving the agency towards enhanced collaboration with industry and refocusing of enforcement priorities.
Senate Confirms Keeling
On October 6, 2025, as part of a larger confirmation of Trump appointees, the Senate
California Enacts SB 237 to Streamline New Oil Well Permits in Kern County and Increase Output
California faces refinery closures, high fuel costs, and reduced oil demand, the combination of which have contributed to concerns regarding potential impacts on price volatility.
The Release Report #3: Reporting Existing Releases
This is the third in a series of blog posts discussing key features of Connecticut’s new release-based cleanup regulations (the “RBCRs”), R.C.S.A. § 22a-134tt-1 et seq.
After a release has been “discovered” (see last post) the next step under the RBCRs is evaluating if and when that release must be reported. This post, and the
Consultation on Modernising the Environmental Permitting Regime for Industrial Activities
On 26 August 2025, the Department for Environment, Food and Rural Affairs (DEFRA) launched a consultation to reform how industrial activities are regulated in England. DEFRA is also working alongside Scotland, Wales and Northern Ireland, so similar changes are likely to take place in those administrations. The consultation excludes waste operations, mining waste operations, radioactive substances activities, water discharge activities, groundwater activities and flood risk activities from reform.
It focuses on industrial emission regulation; including installations, medium combustion plants and specified generators, as well a small waste incineration plants, solvent emission activities, Part B mobile plants and mobile medium combustion plants. These reforms are motivated by the government’s push for a net zero transition and circular economy ambitions the industry is likely to move away from fossil fuel to low carbon alternatives, making the current permitting system less fit for purpose.
We set out below the main strategic goals of the proposed reforms.
DC Circuit Reinstates Title V Emergency Affirmative Defense
On Sept. 5, 2025, the D.C. Circuit reversed EPA’s 2023 rule rescinding the “startup, shutdown and malfunction” (SSM) affirmative defense under the Title V permitting program. The decision carries implications for Title V programs nationwide and for stationary source regulations more broadly.