December 11, 2025

CARB Proposes Rules to Implement California Climate Disclosure Requirements

On Tuesday, the California Air Resources Board (CARB) announced that it will hold a public hearing on February 26, 2026 to consider adoption of a proposed California Corporate Greenhouse Gas Reporting and Climate-Related Financial Risk Disclosure Initial Regulation. At the same time, CARB made the Staff Report (Initial Statement of Reasons) and Proposed Regulatory Text available on its website for public comment during a 45-day comment period that begins on December 26, 2025 and ends on February 9, 2026.

Among the matters addressed in the proposed regulatory text are: (i) the applicability of the disclosure requirements; (ii) definitions; (iii) the calculation, payment and enforcement of fees; and (iv) an August 10, 2026 deadline for providing the GHG emissions disclosures required by SB 253.

As Meredith noted last week, on December 1, 2025, CARB posted an enforcement advisory indicating that it would not enforce the disclosure requirements in SB 261 while an injunction is in effect.

– Dave Lynn

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