What happened at the February 26, 2026, California Air Resources Board (CARB) public hearing and meeting?
On Thursday, February 26, CARB voted to approve regulations implementing California’s two climate disclosure requirements. To implement these laws, the board approved the draft regulation, which provides key definitions, establishes annual compliance fees, and sets deadlines for the first year of reporting.
What are the key elements of the new regulation?
Since these regulations were just issued, what enforcement is expected in 2026?
CARB emphasized that its enforcement guidance remains in effect, which provides accommodation for the first year of reporting. In its press release following the hearing, CARB noted that its priority is to support compliance through stakeholder engagement, and it will exercise enforcement discretion as long as good-faith efforts are made in first-year submissions.
When are climate risk disclosures under SB 261 due?
Enforcement of SB 261 is on a Ninth Circuit injunction, as acknowledged by CARB at the hearing. That injunction does not extend to SB 253. More than 120 climate-related financial risk reports have been voluntarily submitted and are publicly available at CARB’s SB 261 public docket.
What are the plans for future regulations under these laws?
CARB staff noted that additional topics are to be addressed in future guidance, with further SB 253 regulations to be proposed later this year. These are to address Scope 3 GHG emissions reporting, assurance, and reporting deadlines in 2027 and beyond.
CARB SB 253 and SB 261 Resources
See below for links to the notice of staff meeting presentation, the adopted regulatory text, and the press release, along with contact information for subject-matter experts should you require further assistance.
This Frequently Asked Questions blog contains two sections: the first related to the California Air Resources Board’s (CARB) regulatory development for the Corporate Greenhouse Gas Reporting (SB 253) and the Climate-Related Financial Risk Disclosure Programs (SB 261). The second FAQ section concerns only SB 261 reporting.
What is the purpose of the draft regulation posted by the California Air Resources Board (CARB) on December 9, 2025? The draft regulation aims to implement California’s climate disclosure programs, specifically SB 253 (Corporate Greenhouse Gas Reporting) and SB 261 (Climate-Related Financial Risk Disclosure). It outlines requirements and processes for organizations subject to these laws.
What is the public comment period for the regulation? The 45-day public comment period will begin on December 26, 2025, and conclude on February 9, 2026.
How will stakeholders be notified of any updates before formal publication? If CARB makes revisions or updates to any documents in the rulemaking package before formal publication, they will update their rulemaking webpage and notify stakeholders directly who sign up for their listserve at https://public.govdelivery.com/accounts/CARB/subscriber/new.
What topics are covered in the draft regulation? The draft regulation covers definitions of exempt organizations, the provisions for calculating, paying, and collecting fees for each program, and alternative definitions of the fiscal year for SB 253 reporting of corporate greenhouse gas emissions.
Which organizations are required to comply with SB 253 and SB 261? Organizations not listed as exempt in the draft regulation must comply with the reporting and disclosure requirements specified under SB 253 and SB 261. As of December 15, 2025, non-profits, government entities, California-regulated insurance companies, companies in the business of insurance in other states, businesses with only teleworking employees in CA, and businesses with only wholesale electricity transactions in CA are exempt.
Where can stakeholders find updates and further information? Stakeholders can visit CARB’s rulemaking webpage for the latest updates, documents, and notifications regarding the regulation.
California Climate-Related Financial Risk Reporting (SB 261) FAQs
Do I need to post my Climate-Related Financial Risk Report (CRFRR) online by January 1, 2026, to comply with Senate Bill (SB) 261? No, the California Air Resources Board (CARB) issued an Enforcement Advisory on December 1, 2025 (see Enforcement Advisory) to inform covered companies that enforcement of SB 261 (specifically Health and Safety Code section 38533) is paused due to a court injunction. Covered companies are not required to submit or post climate-related financial risk reports by the January 1, 2026, deadline or while the appeal is pending. CARB will not enforce this deadline and will provide further guidance, including a possible alternate reporting date, after the appeal is resolved.
What is the current status of the legal proceedings? On November 18, 2025, the Ninth Circuit Court of Appeals granted an injunction in the case, Chamber of Commerce v. Sanchez, halting enforcement of SB 261 until the appellate proceedings are resolved. The appeal is scheduled for argument on January 9, 2026, which is notably after the legislative January 1, 2026, reporting deadline.
Can entities submit reports voluntarily during this period? Yes, entities may choose to report voluntarily. CARB opened a docket for voluntary submissions of the link to company reports on December 1, 2025. It will be open until July 1, 2026. See Climate-Related Financial Risk Reports (SB 261) Docket
What should we do in the meantime? Together with other stakeholders, we recommend a ‘No Regrets’ approach and continuing the work to complete the CRFRR for your firm. While voluntary reporting is an option, several organizations have already done so by posting on their websites. This ensures you are prepared to submit promptly if and when the program is reinstated.
Where can I find updates or further information? CARB will issue additional information and guidance after the appeal is resolved. Covered companies should monitor CARB communications or their website for updates regarding alternate reporting dates and procedures. See California Corporate Greenhouse Gas (GHG) Reporting and Climate-Related Financial Risk Disclosure Programs.
CARB SB 253 and SB 261 Resources
Please take a look below for links to the notice of public hearing, staff report, and proposed regulatory text, along with contact information for subject-matter experts if you need any more help.
See the most recent program updates.
Today, December 9, the California Air Resources Board (CARB) posted the draft regulation for California’s climate disclosure programs, SB 253 and SB 261, and a public hearing notice for February 26, 2026.
The regulation covers both of California’s climate disclosure laws for Corporate Greenhouse Gas Reporting (SB 253) and Climate-Related Financial Risk Disclosure (SB 261). For the most current information see SCS’s answers to the most frequently asked questions.
If CARB makes any revisions or updates to any of the documents in the rulemaking package before the formal publication on December 26, 2025, they will update their rulemaking webpage and notify stakeholders.
Draft Regulation
The topics covered in the 7-page regulatory document are:
CARB SB 253 and SB 261 Resources
We’ve included below the proposed regulation, the resources CARB has published, and how to get expert support.
Submit Public Comments to CARB
Comment on a CARB topic open for public comment. Please note that your written and oral comments, attachments, and associated contact information (e.g., your address, phone, email, etc.) become part of the viewable public record. Additionally, this information may become available via Google, Yahoo, and any other search engines. If you experience technical issues, submit your comments to the Clerk of the Board via email, and indicate the relevant docket number.
See the most recent program updates.
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