As we noted in an earlier article, certain California businesses were required to submit a Climate-Related Financial Risk Report by January 1, 2026, as required by Senate Bill SB261 and the California Health and Safety Code.
Photo Credit: AI image generated by Google Gemini, Fair Use
However, this requirement has been postponed until further notice as a result of a successful legal challenge by the California Chamber of Commerce. On November 18, 2025 - the same date as a CARB scheduled public workshop on this and related reports - the Ninth Circuit Court of Appeals granted an injunction against enforcement of this requirement as a result of other appeal proceedings related to it.
Those proceedings will not be held until January 9, 2026, after the January 1, 2026 deadline.
CARB will provide further information and a new reporting date once the appeal process is completed. Additionally, no enforcement action will be taken for failure to submit the report by the original date.
In the meantime, CARB has stated that they will accept voluntary reports as of today, Dec. 1, 2025
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