Overview
- On November 18, 2025, the Ninth Circuit granted an injunction pending appeal that halts enforcement of SB 261, with oral argument set for January 9, 2026, and the plaintiffs’ Supreme Court petition withdrawn.
- SB 253 remains in effect, with CARB proposing August 10, 2026 for initial Scope 1 and Scope 2 reports and Scope 3 reporting beginning in 2027.
- CARB’s November 18 workshop and updated FAQs emphasized a “provide what you have” approach and said entities lacking prior data collection may submit a letter instead of 2026 emissions data.
- The scope of the SB 261 injunction remains unclear, and CARB is reviewing whether it can pursue enforcement against non-parties to the lawsuit.
- Preliminary guidance ties “doing business” to in-state sales thresholds and defines revenue as gross receipts, clarifies that parent–subsidiary status does not by itself determine coverage, and posts a preliminary roster of potentially covered entities.