October 17, 2025

Climate Disclosure Rules Update: CARB Delays Initial Rulemaking to Q1 2026

In a notice posted on its website this week, the California Air Resources Board (CARB) indicates that final regulations that were expected to be issued this week will now be delayed until the first quarter of 2026. The notice states:

Following the California Air Resources Board’s (CARB) August 2025 workshop, CARB staff have made available public resources to solicit feedback from stakeholders, including a Climate-Related Financial Risk Report Checklist (09/02/25), a preliminary list of regulated entities and voluntary stakeholder survey tool (09/24/25), and a draft reporting template for Scope 1 and Scope 2 GHG Emissions (10/10/25). Given the large volume of public comments staff have received, and given ongoing input related to identifying the range of covered entities, CARB is proposing an updated timeline for bringing the initial rulemaking (including the fee-related provisions) to the board in Q1 2026. CARB is continuing to take feedback on the draft reporting template for Scope 1 and Scope 2 GHG emissions at CARB’s public docket through 10/27/25. Feedback related to the preliminary list of covered entities can be submitted through an online survey. Other comments or inquiries can be submitted to Climatedisclosure@arb.ca.gov.

The CARB notice does not indicate that the compliance dates for companies will change, even though the work on the regulations remains ongoing. Those companies who are required to make climate disclosures under SB 261 are still expected to submit their reports by January 1, 2026, while those companies that are covered by SB 253 are expected to report their Scope 1 and Scope 2 emissions by June 30, 2026.

– Dave Lynn

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