CARB issues/maintains SB 261 Checklist (updated Nov 17, 2025) clarifying disclosure expectations and acceptable frameworks

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.