As the January 1, 2026, deadline to make the first required disclosure under California’s landmark climate laws approaches, the California Air Resources Board (CARB) has announced that it will host another virtual public workshop on August 21 to discuss its ongoing efforts to develop regulations implementing California Senate Bills (SBs) 253 and 261. SB 253 (updated by SB 219) and SB 261, which are now codified in Sections 38532 and 38533 of the California Health and Safety Code, mandate certain entities to disclose climate-related financial risks by January 1, 2026, and greenhouse gas (GHG) emissions by a date to be determined later in 2026. As CARB announced in its May 29, 2025, workshop, the agency does not intend to issue draft regulations until the end of the year, despite SB 219’s July 1, 2025, deadline. This has left many companies potentially affected by those regulations in the dark regarding whether they will be required to make disclosures. CARB’s August 21 workshop may finally provide clarity on some of the key applicability questions that remain unanswered as these 2026 disclosure deadlines loom.
Based on the workshop announcement distributed to interested parties on August 7, CARB intends to resolve some of the thorniest issues presented by SBs 253 and 261 at its August 21 workshop, namely, what it means to “do business in California,” how revenue will be defined for purposes of triggering disclosure requirements, and considerations related to intra-corporate relationships. CARB indicated the workshop will also present a draft framework for fee regulation, provide an update on the regulatory timeline, and discuss assurance requirements for GHG reporting and the phase-in of Scope 3 emissions reporting, among other items. CARB will accept feedback from the public during the workshop and will open a docket for three weeks following the workshop to accept written comments.
CARB’s virtual workshop is scheduled for August 21 from 9:30 a.m. to 12:30 p.m. PT.
