Publications

CARB Releases Draft Regulations To Implement SB 261 and SB 253

December 10, 2025 Perspectives

On December 9, 2025, CARB released draft regulations to implement SB 261 and SB 253, and announced that the draft regulations may be adopted at the public hearing scheduled for February 26, 2026. 

As a reminder, starting in 2026, business entities organized under U.S. law, doing business in California, and with annual revenues over $500M may be required by SB 261 to make biennial disclosures regarding their climate-related financial risk, and those with annual revenues over $1B will be required by SB 253 to make annual disclosures of their greenhouse gas emissions.

The draft regulations propose: 

  • A framework for SB 261 and SB 253 implementation fees, including definitions of key terms necessary to the fee provisions; 

  • Exemptions for certain entities; and 

  • An initial reporting deadline for SB 253 of August 10, 2026.

The public comment period will be from December 26, 2025, through February 9, 2026, and CARB will hold a public hearing to approve the proposed regulations on February 26, 2026.

The draft regulations and related rulemaking materials are available here, and more information on the public hearing will be posted here.