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Ninth Circuit Pauses California’s SB 261 Climate‑Risk Disclosure Law Pending Appeal

Oral arguments are set for January 9, 2026, creating a temporary pause before the first reports were due.

Overview

  • A brief Ninth Circuit order issued November 18 enjoins enforcement of SB 261, which would have required inaugural climate‑risk reports on January 1, 2026.
  • The order did not extend to SB 253, and CARB signaled an initial SB 253 reporting deadline of August 10, 2026, with rulemaking hearings expected early next year.
  • The scope of the SB 261 injunction remains unclear because the court offered no explanation and the request referenced members of specific plaintiff organizations.
  • Plaintiffs led by the U.S. Chamber withdrew their emergency application to the U.S. Supreme Court after the appellate stay was granted.
  • CARB said it is reviewing the ruling, leaving companies uncertain about who must report and when disclosures may ultimately be required.