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

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.