Friday, November 21, 2025
12:00 - 1:30 p.m.
In 2023, California enacted two separate bills requiring large corporations, including financial institutions, to disclose their carbon footprints and their climate-related financial risk.
The first bill, California Senate Bill 253 (SB 253), titled the “Climate Corporate Data Accountability Act” (“CCDA Act”), applies to companies conducting business in California with annual revenues exceeding $1 billion. The CCDA Act requires covered entities to report their Scope 1, 2, and 3 emissions on an annual basis to the California Air Resources Board (“CARB”). Under the CCDA Act, covered entities are required to begin reporting all Scope 1 and 2 emissions for the entity’s prior fiscal year beginning in 2026 on a date to be set by CARB.
The legislature also enacted California Senate Bill 261 (SB 261), titled “Greenhouse Gases: Climate-related Financial Risk,” which applies to companies with annual revenues exceeding $500 million doing business in California. SB 261 requires these corporations to prepare a climate-related financial risk report disclosing the entity’s climate-related financial risk and its measures adopted to reduce and adapt to climate-related financial risk (the “CRFR Disclosure”). SB 261 requires the CRFR Disclosure to be posted to the entity’s website by January 1, 2026.
While CARB was initially expected to issue regulations to implement these laws by October 14, 2025, they recently announced that regulations would not be issued until the first quarter of 2026. However, the delay in CARB’s regulations do not otherwise change the statutory reporting deadlines. As such, covered entities will still be expected to comply with statutory reporting deadlines despite the lack of regulations issued by CARB.
Please join us at the November Monthly Telephone Briefing when we will discuss where things currently stand with California’s climate disclosure laws, who is covered, the applicable compliance deadlines, and more. Handout to be posted Thursday, November 20th.
