On July 9, 2025, the California Air Resources Board (CARB) released a set of Frequently Asked Questions related to regulatory development and initial reporting obligations under SB 253 and SB 261. While this FAQ does not carry the force of law, it offers helpful insights for companies preparing for upcoming compliance deadlines—in particular, the January 1, 2026 deadline for initial climate-related financial risk reports under SB 261. This guidance is especially timely given CARB’s delay in finalizing the implementing regulations, which were required to be adopted by July 1, 2025.
Key Takeaways for Initial SB 261 Reporting:
1. How should the SB 261 report be published?
CARB will create a public docket on December 1, 2025, where covered entities can post the URL linking to their climate-related financial risk report.
This docket will remain open through July 1, 2026, serving as a centralized location for public access to all submitted reports.
2. What time period should the report cover?
Recognizing that climate-related data is typically collected on a fiscal year basis—and that preparing such reports takes time—CARB has indicated that initial SB 261 reports due by January 1, 2026, may cover either FY 2023–2024 or FY 2024–2025, depending on the company’s reporting cycle.
3. Future rulemaking is still to come:
CARB notes that this guidance applies only to the inaugural reports, and that future implementing regulations may impose additional or modified requirements, consistent with the statutory framework of SB 261.
