CARB Releases Draft Guidance for SB 261 Reporting

On September 2, 2025, CARB released a draft checklist for the initial climate-related financial risk report that must be posted on a company’s website by January 1, 2026.

As a reminder, starting in 2026, business entities organized under U.S. law, doing business in California, and with annual revenues over $500M are required by SB 261 to make biennial disclosures regarding climate-related financial risk. The initial climate-related financial risk report must be made available to the public on the company’s website by January 1, 2026, and a link to the report must be posted to a public docket that CARB will open from December 1, 2025, until July 1, 2026.

CARB’s draft checklist includes a number of clarifications, links to resources related to the frameworks that may be used to meet reporting requirements, and a general checklist for reporting. Among other things, (1) in light of stakeholder feedback regarding the potential burden of conducting a detailed quantitative scenario analysis, and it being potentially duplicative of other reporting requirements, CARB has specified certain minimum disclosure requirements and, (2) in light of stakeholder concerns regarding feasibility and potentially duplicative reporting requirements, CARB has specified that including Scope 1, 2, and 3 emission reporting is not a minimum requirement for initial SB 261 reporting on January 1, 2026.

CARB specified that this guidance is intended to be a “starting point” for covered entities, does not have the force of law, and is subject to change without notice. CARB does not guarantee the accuracy of this guidance and disclaims any responsibility for any errors or omissions in the guidance.

CARB’s draft checklist is available here.