Overview
- On November 18, the court preliminarily enjoined enforcement of SB 261 pending appeal, halting the January 1, 2026 reporting requirement for climate-related financial risk.
- SB 261 covers companies doing business in California with at least $500 million in annual revenue and requires biennial public risk reports.
- The stay’s scope is unclear because the request was made on behalf of members of the plaintiff trade groups, leaving questions for non-members until further guidance.
- SB 253 was not enjoined, with CARB indicating a proposed initial reporting deadline of August 10, 2026 and planning rulemaking hearings in early 2026.
- Plaintiffs withdrew their emergency Supreme Court application after the ruling, and legal advisers recommend continuing preparatory work as SB 261 could become enforceable depending on the Ninth Circuit’s decision.