Overview
- The Ninth Circuit on Nov. 18 enjoined enforcement of SB 261, and CARB’s Dec. 1 advisory says it will not enforce the Jan. 1, 2026 reporting deadline.
- Oral argument on the SB 261 appeal is set for Jan. 9, 2026, after which CARB plans to announce a new reporting date if enforcement resumes.
- CARB’s SB 261 docket is open for voluntary submissions through July 1, 2026, with filers asked to provide a letter on company letterhead and a public web link to their report.
- CARB signaled a narrower ‘doing business in California’ test focused on domicile and in-state sales rather than property or payroll when assessing coverage.
- For SB 253, CARB outlined an initial 2026 submission using available Scope 1 and 2 data, said no assurance is required for that first year, and indicated entities not yet collecting data may submit an explanatory statement.