We are ringing in the New Year with our annual predictions for sustainability legal and compliance professionals. In this post, we provide 26 predictions to inform sustainability compliance in 2026 (and beyond), in particular...more
As many were settling back into work after the Thanksgiving holiday, the California Air Resources Board (CARB) published an Enforcement Advisory and opened up its public docket for voluntary submissions of SB 261 climate risk...more
The California Air Resources Board held its third workshop last week on California’s pending corporate climate disclosure mandates. Health & Safety Code 38532 (SB 253) requires greenhouse gas emissions disclosures, while...more
On November 18, 2025, the U.S. Court of Appeals for the Ninth Circuit granted a motion for injunction pending appeal that temporarily pauses enforcement of California Senate Bill 261 (SB 261) while the court considers a legal...more
On November 18, 2025, the U.S. Court of Appeals for the Ninth Circuit paused the enforcement of the California Climate-Related Financial Risk Act (SB 261) while the lawsuit challenging SB 261 and the Climate Corporate Data...more
In late October, ExxonMobil filed a complaint in the U.S. District Court for the Eastern District of California against state officials challenging the state’s new carbon emissions disclosure law (SB 253) and climate risk...more
The California Air Resources Board (CARB) recently released a draft list of 4,159 public and private companies that do business in the state and that it believes must comply with California’s laws requiring disclosure of...more
On September 24, 2025, the California Air Resources Board (CARB) — the state regulator responsible for implementing California’s new mandatory climate disclosure regulations — released a preliminary list of about 4,100...more
The California Air Resources Board (“CARB”) hosted a public workshop on August 21, 2025 to provide information on Senate Bills 253, 261 and 219 (the “California climate laws”) and solicit feedback from consumers and...more
The California Air Resources Board (CARB) released a list this week identifying which entities the agency believes are subject to the state’s climate disclosure laws — SB 253 and SB 261. The list can be downloaded here....more
On September 2, the California Air Resources Board (CARB) published its long-awaited draft guidance on compliance with California’s Climate‐Related Financial Risk Act (S.B. 261) (codified in Health & Safety Code Section...more
On September 2, 2025, the California Air Resources Board ("CARB") released draft guidance on SB 261 (the Climate-related Financial Risk Act) called a "Draft Checklist" that entities can use in preparing their climate-related...more
The California Air Resources Board (CARB) recently released a Draft Checklist to assist companies in preparing climate-related financial risk reports under Senate Bill 261, codified at California Health and Safety Code (HSC)...more
On September 2, 2025, the California Air Resources Board (CARB) released a draft checklist to guide companies within the scope of SB 261 in preparing climate-related financial risk reports. This law, codified in Health and...more
Last night, the California Air Resources Board (CARB) released draft guidance on the Climate‐Related Financial Risk Act (Health & Safety Code Section 38533/Senate Bill 261). This disclosure mandate will require subject...more
This series seeks to identify legal questions that can add definition and value to the good work that sustainability teams are doing. ...more
In-scope entities should keep preparing for compliance with Senate Bills 253 and 261 as the lawsuit proceeds past an initial summary judgment motion....more
You might recall that, in 2023, California Governor Gavin Newsom signed into law two bills related to climate disclosure: Senate Bill 253, the Climate Corporate Data Accountability Act, and SB261, Greenhouse gases:...more
On October 7, 2023, Governor Gavin Newsom signed into law a trio of climate-related bills that will impact what companies doing business in California must (or can) say about their greenhouse gas (GHG) emissions and the...more
California Governor Gavin Newsom recently signed into law two core bills of the state's “Climate Accountability Package, Senate Bill 253 (SB 253) and Senate Bill 261 (SB 261). As they currently stand, these laws impose...more
On October 7, 2023, California Governor Gavin Newsom signed two new climate reporting bills into law: Senate Bill (SB) 261, Greenhouse gases: climate-related financial risk and SB 253, the Climate Corporate Data...more
Governor Gavin Newsom has signed the Climate Corporate Data Accountability Act (SB 253) and the Climate-Related Financial Risk Act (SB 261) into law, which means the California Air Resources Board (CARB) is now tasked with...more
California Governor Gavin Newsom signed into law two watershed climate bills on October 7, 2023 that will require companies with significant revenue to make climate-related disclosures starting in 2026. The stated purpose of...more
California is poised to become the first state to require large companies to disclose greenhouse gas (GHG) emissions from direct operations, supply chains and employees and report on climate-related financial risk and any...more