California’s climate accountability framework is at a pivotal moment. On November 18, 2025, the California Air Resources Board (CARB) hosted its latest public workshop to refine implementation details for SB 253 (Climate Corporate Data Accountability Act) and SB 261 (Climate-Related Financial Risk Act). This latest workshop session (CARB’s third public workshop) provided new clarity on reporting templates, deadlines, and definitions for companies gearing up for compliance in 2026. CARB also published FAQs Regarding California Climate Disclosure Requirements (updated November 27, 2025), which provides additional information that supplements and supports the workshop.
On the same day, the Ninth Circuit Court of Appeals granted approval of an injunction to halt enforcement of SB 261 pending appeal, while denying the portion of the motion related to SB 253. This split decision introduces uncertainty for thousands of businesses while reinforcing the need for proactive compliance planning.
In this update, we unpack key workshop takeaways, the legal developments, and what they mean for companies navigating California’s evolving climate disclosure regime.
Key Updates from CARB Workshop
SB 253: Climate Corporate Data Accountability Act
- Companies that were not collecting or planning to collect data as of CARB’s Enforcement Notice (dated December 5, 2024) do not need to submit Scope 1 and 2 emissions in 2026. However, such companies will need to submit a statement on company letterhead attesting that they were not collecting or planning to collect data at the time of publication of the Enforcement Notice.
- CARB anticipates issuing an initial regulation in Q1 2026, with more detailed regulations for 2027 and beyond to come later in 2026.
- Proposed reporting deadline for initial filings is now August 10, 2026 (previously June 30, 2026).
- CARB clarified that, exercising enforcement discretion, limited assurance is not required for 2026 reporting, provided the company was not already collecting or planning to collect such assured data at the time of the Enforcement Notice.
SB 261: Climate-Related Financial Risk Disclosure
For an overview of the two disclosure laws and previous updates from CARB, please see this Trinity article from September 29, 2025.
Legal Development: Injunctive Relief
- On November 18, the Ninth Circuit Court of Appeals issued an injunction temporarily halting enforcement of SB 261.
- The US Chamber of Commerce and other business groups had filed an emergency application with the US Supreme Court the week prior to stop enforcement of SB 261 and SB 253.
- SB 261 enforcement is paused. The Ninth Circuit is not expected to hear oral arguments until January 9, 2026, after the SB 261 reporting deadline of January 1 has passed.
- SB 253 remains in effect and is unchanged at this time.
Recommended Next Steps
1. Stay the course with preparation of SB 261 disclosures.
The injunction may appear to offer short-term relief, but the law remains on the books. If the injunction is lifted soon after the January 9, 2026 hearing, companies may face a compressed timeline to publish disclosures. Further, completing work already begun on the disclosure is more efficient than stopping and restarting later. Prepare to publish or post the SB 261 report on the respective company’s website, even if CARB’s docket is not open or available by January 1, 2026, due to the court ruling.
2. Engage legal teams.
Legal counsel is critical to fully understanding the business-specific implications of the Ninth Circuit’s injunction and upcoming appeal. They can help track litigation developments, manage risk exposure, and prepare contingency plans in case of rapid shifts in compliance obligations.
3. Maintain momentum on SB 253 compliance efforts.
Begin or continue data collection efforts for preparing Scope 1 & 2 GHG emissions for FY 2025. Begin to implement procedures and systems to collect data needed for calculating Scopes 1, 2, and 3 emissions for FY 2026. Proactively assess your organization’s readiness for meeting limited assurance standards in the future through an internal or third-party assessment. This process can help identify gaps and provide recommendations for ways to improve.
Why Act Now
Despite the Ninth Circuit’s injunction on SB 261, uncertainty remains and waiting carries real risks. Operationally, delaying preparation could lead to rushed compliance if enforcement resumes quickly. Reputationally, stakeholders expect transparency regardless of legal ambiguity. Financially, penalties and litigation costs remain possible if companies fall behind.
Engage Trinity to work with your legal team and sustainability leaders now to position your organization to respond swiftly when the court rules in January. The Trinity team possesses extensive expertise in mandatory and voluntary environmental and climate data disclosures. Trinity can also assist companies across diverse industry sectors in preparing for company-wide disclosure requirements. If you would like to discuss SB 253 and SB 261 and how to adjust your reporting strategy, please contact us here.
