Climate Disclosure Whiplash: 30+ Questions on the California Corporate Greenhouse Gas Reporting Program (SB 253) and Climate-Related Financial Risk Disclosure Program (SB 261)
Entities preparing to comply with new California climate disclosure requirements face looming deadlines amid uncertainty. The compliance deadline for climate-related financial risk reports specified in California Senate Bill 261 is January 1, 2026, but enforcement of that deadline has been stayed pending an appeal. Scope 1 and Scope 2 greenhouse gas emissions disclosures are due August 10, 2026, with Scope 3 disclosures due in 2027 (as required by California Senate Bill 253). SB 253 and SB 261 (each as amended in September 2024 by California Senate Bill 219) are codified in California Health & Safety Code § 38532 and § 38533, respectively.
This alert sets forth questions and answers on climate-related disclosures required under SB 253 and SB 261, and reflects guidance from the California Air Resources Board staff including in CARB’s FAQs About Regulatory Development and Initial Reports, SB 261 disclosure checklist, draft Scope 1 and Scope 2 emissions reporting template and enforcement notice, and as discussed in three half-day public workshops hosted by CARB staff on November 18, 2025, August 21, 2025 and May 29, 2025.
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Head of Regulatory Transactions Group
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