CARB announced approval/adoption of an initial regulation package for California’s corporate climate disclosure programs (SB 253 and SB 261) that establishes administrative/implementation fee structures and related program definitions. Although the fee regulation is program-wide, it is directly relevant to SB 261 because it supports administration of the SB 261 disclosure program and CARB reiterates that, pursuant to a court order, CARB is not enforcing SB 261 and reporting is voluntary at this time. Compliance teams should account for CARB’s movement on program administration and budgeting (fees) while tracking the injunction’s effect on SB 261 enforcement and any subsequent implementation updates.
CARB approved/adopted the initial implementing regulation package for California’s corporate climate disclosure laws (SB 253/SB 261). The board materials and CARB news release indicate the initial regulation establishes administrative program elements (including fee-related administration/implementation concepts and related definitions) and acknowledges SB 261 reporting remains voluntary because CARB is not enforcing Health & Safety Code §38533 while a Ninth Circuit injunction is in place. Compliance teams should track the adopted implementing regulation package because it operationalizes CARB’s program administration and may affect covered-entity readiness and budgeting (fees), even though SB 261 enforcement is paused.
CARB’s SB 261 docket page was updated (noted as Updated 2/10/26) and continues to provide operational instructions for covered entities that voluntarily submit climate-related financial risk reports while SB 261 enforcement is paused due to a Ninth Circuit injunction. The docket materials describe how to submit a report link/attestation, review/processing timelines, and where approved submissions are posted. Compliance teams should treat this as the current CARB-endorsed process for voluntary submissions and monitoring of SB 261 implementation posture pending litigation outcomes.
CARB updated its SB 261 public docket page (marked Updated 2/10/26) to restate its current operational posture during the injunction period and to provide practical instructions for voluntary submissions (e.g., submitting a company statement and a public link to the SB 261 report hosted on the entity’s website). The page also describes administrative handling, including an indicated review timeline before public release and a stated docket submission window (Dec 1, 2025 to Jul 1, 2026). This update is operationally important for entities choosing to submit voluntarily while enforcement is stayed.
CARB provides a publicly accessible 'approved comments' listing for the SB 261 docket that functions as the public-facing repository of voluntary submissions while enforcement is enjoined. This listing supports compliance transparency by showing submitted materials and reinforcing the expectation that entities host their reports publicly and provide CARB the link/statement for docketing.
CARB established and maintains a dedicated SB 261 public docket to accept voluntary submissions during the injunction period. The docket describes what entities should submit (a company statement and a public link to the SB 261 climate-related financial risk report hosted on the company website) and notes CARB’s review process prior to public posting. Operationally, this creates the mechanism CARB expects for voluntary submissions while enforcement is paused, and it displays a submission window through July 1, 2026.
CARB updated its “Climate-Related Financial Risk Reports (SB 261) Docket” page (noted as updated 2/10/26) that operationalizes voluntary SB 261 report submissions while enforcement is enjoined. The page provides submission mechanics (e.g., submit a company statement and a public URL to the SB 261 report hosted on the company’s website), states CARB will review submissions for quality/completeness prior to public posting, and displays a submission window on the page (“Deadline for Submittals - Dec 1, 2025 to Jul 1, 2026”). For compliance teams, this creates an official CARB intake/public posting pathway and a clear voluntary submission deadline window to track even during the injunction period.
CARB created/maintains a public-facing docket to accept voluntary submissions related to SB 261 climate-related financial risk reports while enforcement of the statutory requirement is enjoined. The docket provides instructions for submitting a company statement and a public URL to the report hosted on the company’s website, and it specifies a submission window of December 1, 2025 through July 1, 2026. This matters for compliance teams because it establishes a CARB intake mechanism and timing expectations for entities choosing to report during the injunction period, and it provides a central location for CARB-referenced support materials (e.g., enforcement advisory, checklist/FAQ) and for tracking what peers are submitting.
CARB’s SB 261 public docket page (updated Feb. 10, 2026) operationalizes voluntary submissions of SB 261 climate-related financial risk report links and related materials while enforcement is enjoined. The page specifies a submission window from Dec. 1, 2025 through Jul. 1, 2026, and describes process mechanics (e.g., report must be posted on the entity’s own website and submitted via link; CARB review period before public posting). For compliance teams, this provides a CARB-supported pathway to publish and log SB 261 reports voluntarily and clarifies timing/processing expectations during the injunction period.
CARB published a Notice of Public Hearing for the proposed initial regulation package implementing California’s corporate climate disclosure programs, including the SB 261 Climate-Related Financial Risk Act components. This is a formal rulemaking step that opens/frames stakeholder participation in CARB’s development of implementing regulations (e.g., definitions, program administration, and related procedural details). Compliance teams should monitor the rulemaking docket and hearing process for any changes that could affect SB 261 applicability interpretations, administrative processes, or future compliance expectations (noting SB 261’s separate statutory reporting obligation and litigation-related enforcement posture discussed in other CARB materials).
CARB issued an Enforcement Advisory stating it will not enforce Health & Safety Code § 38533 (SB 261) against covered entities for failing to post and submit climate-related financial risk reports by the statutory January 1, 2026 deadline because a Ninth Circuit injunction is in place pending appeal. CARB also indicated it will provide further information, including an alternate reporting date as appropriate after the appeal is resolved. This affects compliance planning by pausing enforcement risk for the statutory deadline while signaling that CARB expects reporting to resume on a revised timeline once litigation is resolved.
CARB published an Enforcement Advisory for SB 261 stating it will not enforce Health & Safety Code § 38533 against covered entities for failure to post and submit climate-related financial risk reports by the statutory January 1, 2026 deadline, citing a Ninth Circuit injunction. CARB indicates SB 261 reporting is voluntary while the injunction is in place, and signals that further information (including an alternate reporting date) may be provided after the appeal is resolved. Compliance teams should continue preparing SB 261-aligned disclosures but should treat CARB enforcement for missed Jan 1, 2026 submission/posting as paused while monitoring for post-appeal updates.
CARB published an Enforcement Advisory stating that, due to a Ninth Circuit injunction, it will not enforce Health & Safety Code § 38533 (SB 261) against covered entities for failure to post/submit climate-related financial risk reports by the statutory January 1, 2026 deadline. CARB indicates it will provide further information, including an alternate reporting date, after the appeal is resolved. This materially affects compliance planning and enforcement risk for in-scope entities, while leaving open voluntary reporting during the injunction period.
CARB updated its FAQ document for the California Corporate Greenhouse Gas Reporting and Climate-Related Financial Risk Disclosure Programs (SB 253/SB 261). The FAQs provide CARB’s implementation interpretations on topics such as program definitions and how CARB is approaching regulatory development and initial reporting expectations relevant to SB 261. Compliance teams should use the FAQs as an official reference for CARB’s current interpretations and planned regulatory approach when designing SB 261 reporting processes and governance.
CARB published an updated SB 261 climate-related financial risk report checklist (posted Sept. 2, 2025; updated Nov. 17, 2025) intended to guide covered entities on how to prepare SB 261 climate-related financial risk reports. The checklist provides CARB’s implementation guidance on report content and how to handle incomplete/early-stage assessments (e.g., disclosing limitations/assumptions), points to use of industry-specific guidance where applicable, and discusses acceptable frameworks (e.g., TCFD/IFRS-aligned approaches or other qualifying reports as described in the statute). Compliance teams can use this as an official CARB reference for report structure and documentation approach while enforcement is otherwise addressed via separate CARB communications.
CARB published an updated FAQ document (updated Nov 17, 2025) addressing regulatory development and initial reporting considerations for California’s climate disclosure requirements, including SB 261. The FAQ provides CARB staff interpretations relevant to scoping (e.g., concepts used to evaluate revenue/doing business in California) and clarifies practical questions for entities planning disclosures. Compliance teams should use the FAQ as current CARB interpretive guidance while tracking formal regulations and any post-injunction changes to enforcement posture or timing.
CARB issued an updated SB 261 'Climate Related Financial Risk Report Checklist' (updated Nov 17, 2025) intended to guide covered entities on the contents of climate-related financial risk reports. The checklist is positioned as practical guidance for preparing disclosures and references acceptable reporting frameworks (e.g., TCFD/IFRS S2 or equivalent) and the types of governance/strategy/risk management/metrics information CARB expects entities to address. Compliance teams can use this checklist to structure initial reports and gap-assess existing climate risk disclosures while formal rulemaking and enforcement remain impacted by the injunction.