CARB issues SB 261 Enforcement Advisory stating non-enforcement of Jan 1, 2026 deadline due to Ninth Circuit injunction; reporting voluntary pending appeal

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.