ESG Litigation & Enforcement Tracking

CARB Counts on Public Comments on GHG Emissions and Financial Risk Disclosures

In May 2025, the California Air Resources Board (CARB) hosted a virtual public workshop on its plans for implementing California’s greenhouse gas emissions (SB 253) and climate-related financial risk disclosures (SB 261) programs. In the workshop, CARB presented “initial staff concepts” for the implementation of SB 253 and SB 261, including defining “doing business in California,” “total annual revenue,” and corporate parent-subsidiary relationships. CARB also suggested it may look to the International Sustainability Standards Board’s (ISSB) standards instead of the Task Force on Climate-related Financial Disclosures (TCFD) as a framework for SB 261 implementation. CARB has not yet begun formal rulemaking for SB 253 or SB 261. The rulemaking timeline for SB 253 was delayed from July 1, 2025 to the end of 2025, and CARB has not yet decided whether it will issue guidance or regulations for SB 261. This delay in regulations prolongs the uncertainty for companies seeking to determine whether they are covered, what reporting requirements apply and when, and how to prepare for compliance. CARB indicated that “stakeholder input is critical” to the initial staff concepts and other interpretive issues, and stated that it plans to hold additional workshops or stakeholder sessions this year.