CARB issues SB 261 Enforcement Advisory pausing enforcement of the January 1, 2026 reporting deadline due to Ninth Circuit injunction

CARB published an Enforcement Advisory stating it will not take enforcement action against covered entities for failing to post and submit SB 261 climate-related financial risk reports by the statutory January 1, 2026 deadline, citing a Ninth Circuit injunction against enforcement while the appeal is pending. CARB also indicates it will provide further information, including an alternate reporting date, after the appeal is resolved. Compliance teams should treat the statutory obligation as still on the books but recognize CARB’s stated enforcement posture and monitor litigation outcomes and CARB follow-on timing communications.