On December 9, 2025, the California Air Resources Board (CARB) released its highly anticipated draft of proposed regulations to implement California’s climate risk reporting SB 261 and emissions reporting SB 253 bills. CARB also issued an accompanying staff report outlining rationale used in its decision-making process. The draft regulation builds on the guidance issued by CARB in its late November public workshop. Several key aspects of the rules and nuances are clarified in the regulations, including but not limited to, applicability criteria, definitions of “revenue” and “doing business in California”.

While enforcement for the climate risk rule (SB 261) is on hold due to a legal injunction pending a hearing on January 9, 2026, the emissions reporting rule (SB 253) remains in effect. The new proposed regulatory deadline for SB 253 has been set to August 10, 2026. The draft regulations will be formally published on December 26, 2025, which will be followed by a 45-day public comment period ending on February 9, 2026. A public hearing is scheduled on February 26, 2026, when adoption of the Climate Data and Financial Risk Reporting Fee Regulation will be considered.

Join Trinity’s webinar on January 14, 2026, as we unpack the key takeaways of the regulations and what they mean for companies subject to these requirements. If you have any questions or need support navigating these rules, please contact our experts here.