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.
