United States: Climate Change

California's air quality regulator has unveiled its approach to phased Scope 3 emissions reporting under SB 253, beginning with just five of fifteen categories in 2027 while leaving full implementation without a committed timeline. The proposal introduces materiality-based exclusions, dual Scope 2 calculation methods, and a five-standard assurance framework that raises questions about engagement scope and cost implications for covered entities.

California's Air Resources Board held a workshop on July 21, 2026, to discuss the regulatory framework for greenhouse gas reporting under the Climate Corporate Data Accountability Act (SB 253). CARB previewed its approach to 2027 rulemaking while confirming the delayed November 10, 2026 deadline for inaugural Scope 1 and Scope 2 emissions reporting, with draft regulations emphasizing alignment with the Greenhouse Gas Protocol and phased implementation of Scope 3 reporting requirements.

New York State has amended its SEQRA regulations to formally incorporate environmental justice considerations and climate impact assessments into the environmental review process. The changes require agencies to evaluate whether proposed actions may disproportionately burden disadvantaged communities and align with statewide climate goals. These amendments, effective June 12, 2026, introduce new Environmental Assessment Forms and expand the list of Type II actions exempt from review.

Jones Day's Climate Report for Q2 2026 examines critical regulatory developments including the UK's new Carbon Border Adjustment Mechanism and EU Taxonomy amendments, alongside landmark litigation such as Maryland's dismissal of climate suits against energy companies and challenges to EPA's repeal of greenhouse gas standards. The report also explores emerging transactional trends in climate risk pricing, nature-based infrastructure financing, and green data center regulations across multiple jurisdictions.

California's Air Resources Board has announced a three-month extension for the first greenhouse gas emissions reports required under the state's Climate Corporate Data Accountability Act, moving the deadline from August 10, 2026, to November 10, 2026.

California Governor Gavin Newsom’s return-to-office order, which requires approximately 90,000 state employees to work primarily in person at least four days per week, has sparked significant legal pushback.

The SEC has formally proposed to rescind its comprehensive climate-related disclosure rules adopted in March 2024, citing concerns about statutory authority and regulatory overreach. This proposal would eliminate all mandated climate disclosure requirements for public companies, including greenhouse gas emissions reporting, climate risk assessments, and financial statement disclosures related to severe weather events.

New York State's 2026 Enacted Budget introduces significant amendments to the Climate Leadership and Community Protection Act, adjusting greenhouse gas emission reduction timelines, changing accounting methodologies, and extending regulatory deadlines. These revisions will reshape how the state measures climate progress and implements environmental permitting decisions, potentially affecting projects that were previously denied or remain pending approval.

As the 2026 midterm elections approach, Democratic lawmakers are already laying groundwork for intensified congressional investigations into energy and environmental policy decisions made during the Trump Administration.