Push for Transparency Led by Industry-Based Task Force on Climate-Related Financial Disclosures

On November 18, the United States Court of Appeals for the Ninth Circuit granted a partial injunction blocking enforcement of California’s climate-related financial risk disclosure law (SB 261). Inaugural reports under SB 261 were intended to be published by reporting entities by January 1, 2026. Akin wrote on the subject in full detail here.

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On December 9, 2025, the California Air Resources Board (CARB) announced that it will convene a public hearing on February 26, 2026, to consider approving the adoption of regulations governing California’s climate-related disclosure statutes: SB 253 and SB 261.[1] CARB also published the proposed regulatory text, which we explore below.

On December 1, 2025, the California Air Resources Board (CARB) released an Enforcement Advisory clarifying that it will not enforce SB 261 against covered entities for failing to publish climate-related financial risk reports by the January 1, 2026, statutory deadline.¹