Speaking Sustainability

On December 1, 2025, the New York Department of Environmental Conservation (NYDEC) finalized regulations for its greenhouse gas (GHG) emissions reporting program under the Climate Leadership and Community Protection Act (CLCPA).¹ These rules establish mandatory annual GHG reporting requirements for certain facilities and suppliers beginning June 1, 2027, with earlier compliance milestones for Large Emission Sources and anaerobic digestion, liquid waste storage and certain solid waste landfill operators taking effect in late 2026. We previously wrote about the draft regulations here.

On January 9, 2026, the Ninth Circuit heard oral argument in an appeal challenging California’s climate reporting laws: SB 253 (emissions disclosure) and SB 261 (climate‑related financial risk reporting).¹ The court previously stayed enforcement of SB 261 pending appeal, leaving SB 253 in place for now. We have covered the procedural background leading to oral argument here.

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.

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

On November 18, 2025, the U.S. Court of Appeals for the 9th Circuit issued an order enjoining the state of California from enforcing its climate-related financial risk reporting law, SB 261, while the Court hears full arguments on the merits. SB 261 requires covered entities (i.e., companies with over $500 million in annual global revenue who “do business in California”) to publish climate-related financial risk reports on their websites by January 1, 2026.¹

On November 18, 2025, the California Air Resources Board (CARB) will host its third virtual workshop addressing regulations under SB 253 (Climate Corporate Data Accountability Act) and SB 261 (Climate-Related Financial Risk Act). The session follows CARB’s October 2025 decision to delay publishing draft regulations, which originally were slated for board consideration in December 2025.

The California Air Resources Board (CARB) recently added a notice to its webpage indicating that it will further delay the issuance final regulations for California’s climate-related reporting statutes (Senate Bills 253 and 261), likely until the first quarter of 2026.

Despite litigation challenges and regulatory delays, deadlines are not shifting for reporting under California’s Climate Disclosure laws. Most recently, California Air Resources Board (CARB) delayed publishing draft regulations for SB 253 and SB 261, citing extensive public comments and ongoing input on covered entities. Despite the fact that CARB expects to publish an updated timeline for final regulations in early 2026, inaugural reporting under SB 261 is due by January 1, 2026.