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The California Air Resources Board (CARB) has opened a public docket for entities that may choose to voluntarily submit their Climate-Related Financial Risk Report under Senate Bill (SB) 261 (Stern, Stats. 2023, ch. 383, codified in Health and Safety Code section 38533).
On November 18, 2025, the Ninth Circuit Court of Appeals issued an order in Chamber of Commerce v. Sanchez, Case No. 25-5327 (9th Cir. 2025), granting an injunction against the enforcement of Senate Bill (SB) 261 (Stern, Stats. 2023, ch. 383, codified in Health and Safety Code section 38533) during the pendency of appellate proceedings in that . This injunction applies solely to SB 261 (Health and Safety Code section 38533). SB 253 (Health and Safety Code section 38532) remains in effect and is not impacted by this order. Argument in that appeal is set for January 9, 2026, after the January 1, 2026, reporting deadline set by section 38533. In light of the Court’s order, will not enforce Health and Safety Code section 38533 against covered entities for failing to post and submit reports by the January 1, 2026, statutory deadline, as provided in CARB’s enforcement advisory with guidance to stakeholders.
submission of climate-related financial risk reports into the docket described is optional for covered . CARB will provide further information—including an alternate for reporting, as appropriate—after the appeal is .
For additional information, please visit the California Corporate Greenhouse Gas (GHG) Reporting and Climate Related Financial Risk Disclosure Programs webpage and CARB’s Resources. CARB continues to seek feedback on these programs, which can be submitted to climatedisclosure@arb.ca.gov.
Background
The Climate-Related Financial Risk Disclosure Program authorized by SB 261 applies to both public and private U.S. companies that do business in California with annual revenues in excess of $500 million. This program will require companies to publish biennial climate-related financial risk reports. SB 219 (Wiener, Stats. 2024, ch. 766) amended parts of SB 261, including adjustments to regulatory timelines, and other provisions.
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