On July 9, 2025, the California Air Resources Board (CARB) released a series of frequently asked questions (FAQs) related to its efforts to implement California’s landmark climate disclosure laws, SB 253 (requiring reporting of GHG emissions) and SB 261 (requiring disclosure of climate-related financial risks). Although draft implementing regulations are not anticipated before December 2025, public and private companies subject to the laws’ requirements face their first compliance deadlines beginning January 1, 2026.
Published nine days after CARB missed its most recent statutorily mandated deadline to adopt implementing regulations for SB 253, the FAQs reveal that CARB has made seemingly little rulemaking progress since its May 29, 2025, virtual public workshop addressing SBs 253 and 261. The FAQs confirm that CARB is still in “the informal, information gathering stage” and reiterate, but do not expand upon, “initial staff concepts” first introduced in the May workshop.
The FAQs offer little insight to companies seeking regulatory clarity on exactly when their GHG disclosures under SB 253 will be due, simply reiterating that SB 253 requires disclosure of 2025 Scope 1 and Scope 2 GHG emissions starting in 2026 (for 2025 emissions), with limited assurance, and disclosure of Scope 3 emissions beginning in 2027 (for 2026 emissions).
For SB 261, CARB reiterated the January 1, 2026, deadline for companies to disclose biennial climate-related financial risks on their public-facing websites. However, CARB announced for the first time in the FAQs that it intends to launch a public docket for companies to post a link to their climate risk disclosure, even though this is not a statutory requirement of SB 261. The public docket, which CARB states “will help support transparency by providing one location for the public to be able to review all climate risk reports,” will be open from December 1, 2025, through July 1, 2026. CARB also explicitly recognized in the FAQs that since climate risk data is often collected on a fiscal year basis and takes time to process, the January 1, 2026, disclosures may cover either fiscal years 2023/2024 or 2024/2025.
The FAQs make clear that CARB is unlikely to introduce a proposed rule anytime in the immediate future, leaving companies that still are seeking to learn whether they will be covered by SBs 253 and 261 in the dark as compliance deadlines loom. While this timeline is frustrating for those companies that are anxiously trying to determine how to proceed, CARB makes clear in the FAQs that it is still actively seeking stakeholder input, and the extended rulemaking timeframe affords additional opportunities to provide input to CARB as it seeks to shape the rules.
