CARB issues SB 261 Enforcement Advisory: enforcement paused due to Ninth Circuit injunction; Jan 1, 2026 deadline not enforced; alternate reporting date TBD

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.