United States: Climate Change

California's climate disclosure regulations have taken effect, establishing critical definitions for corporate greenhouse gas reporting under SB 253 and climate-related financial risk disclosure under SB 261. With the first emissions reports due November 10, 2026, companies must navigate complex applicability tests, voluntary reporting portals, and evolving regulatory expectations while legal challenges continue to unfold. Understanding which entities are covered, how to structure submissions, and what step

California's Air Resources Board has released new guidance for entities preparing their 2026 greenhouse gas emissions reports under the Climate Corporate Data Accountability Act, with submissions due November 10, 2026. The guidance includes an instructional video, optional online reporting form, and confirms enforcement discretion for the first reporting cycle, allowing companies to submit data they were already collecting without requiring limited assurance.

California's climate disclosure regime is undergoing rapid transformation through regulatory developments, implementation guidance, and litigation. This legal update examines the latest developments affecting SB 253 and SB 261, including the California Air Resources Board's revised rulemaking and extended compliance timelines that will impact companies doing business in California.