CA SB 253 and 261 in the News: November 2025 Updates

The California Air Resources Board ("CARB") and the state’s climate reporting requirements have been in the news this week.

Here’s what companies need to know:

Court Blocks CA SB 261 Enforcement

• The headline: The U.S. Court of Appeals for the Ninth Circuit granted an injunction blocking the enforcement of SB 261.
  • What you should know:
    • SB 261 (disclosure of climate-related financial risks) is effectively paused.
    • The injunction is pending appeal, and oral arguments are scheduled for January 9, 2026 (after the original compliance date, though this could change). 
    • SB 253 (disclosure of greenhouse gas emissions) was not affected by the injunction.
  • Your next steps: Many companies are continuing to prepare disclosures for possible publication in early January if the injunction is lifted. Connect with your legal team for additional guidance and reach out to us for preparation support.

CARB's Recent Workshop: Implementation Updates

• The headline: CARB’s 11/18 public workshop on California’s climate disclosure rules.
  • What you should know:
    • SB 253 (Corporate Data Accountability Act) reporting timeline was pushed back to August 10, 2026.
    • Reporting entities with a fiscal year ending after February 1, 2026 can elect to report data from their 2025 fiscal year.
    • CARB expressed leniency in SB 253 reporting format, limited assurance requirements, and reporting expectations for the first year, with reference to their December 2024 Enforcement Notice. The details can be found in the workshop presentation (linked here).
    • CARB shared that the initial preliminary list of regulated entities published in September should not be used as a compliance tool and released additional guidance on how to determine corporate reporting requirements (details here).
    • CARB covered other updates related to fee structure, parent/subsidiary reporting considerations, and revised FAQ and reporting checklist.
  • Your next steps: Connect with your legal counsel to determine how these updates may impact your specific reporting requirements and reach out to Third Economy to align on your disclosure readiness plan.

We are here to help when you and your company when you are ready to get started. For more information on these rules, check out our past insights. 

Disclaimer: The information provided does not, and is not intended to, constitute legal advice; instead, all information, content, and materials available are for general informational purposes only.