On December 1, 2025, CARB issued an Enforcement Advisory stating that it will not enforce SB 261 against covered entities that do not post and submit reports by the January 1, 2026, statutory deadline.

As a reminder, 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 starting on January 1, 2026, regarding their climate-related financial risk.  

CARB is not enforcing the January 1, 2026, statutory deadline in light of the Ninth Circuit injunction against enforcement of SB 261 during the pendency of the appeal in Chamber of Commerce v. Sanchez, Case No. 25-5327 (9th Cir. 2025). Depending on the outcome of the appeal, after the appeal is resolved, CARB plans to provide an alternate reporting date.

CARB’s December 1 Enforcement Advisory can be found here.

For entities that choose to voluntarily post and submit an SB 261 report, CARB has opened a public docket for entities to submit links to the SB 261 reports posted on their websites. Further information on making a submittal to CARB’s public docket can be found here.