US-CA-SB261Enacted; enforcement enjoined pending appeal (Ninth Circuit order of 18 November 2025); CARB not enforcing

California SB 261 – Climate-Related Financial Risk Act

United States (California) · California Air Resources Board (CARB)

California law requiring US-based companies with more than $500 million in annual revenue that do business in the state to publish a climate-related financial risk report every two years, following the TCFD framework or an equivalent. The Ninth Circuit enjoined enforcement while the Chamber of Commerce appeal is pending, so CARB has not enforced the 1 January 2026 deadline. Companies may post reports voluntarily to a CARB docket opened 1 December 2025.

Category: Mandatory climate risk disclosure
Enforcement: Mandatory by statute; enforcement suspended by court injunction
Effective date: Statutory first report due 1 January 2026 and every two years after; CARB is not enforcing that date and will announce an alternate reporting date after the appeal is resolved
Covered entities: US companies doing business in California with revenue >$500m
Notes: Chamber of Commerce v. Sanchez, 9th Cir. No. 25-5327; argued 9 January 2026; no merits ruling as of 23 September 2026. CARB's initial regulation (adopted 26 February 2026, OAL approval pending) also sets SB 261 applicability and fees.

Sources

https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202320240SB261 ↗
Primary regulator or official text

Verified 2026-09-23Something wrong here? Report it

Related regulations

US-CA-SB253

California SB 253 – Climate Corporate Data Accountability Act

United States (California) · California Air Resources Board (CARB)

Enacted; CARB initial regulation adopted 26 February 2026, withdrawn from OAL review in June 2026 for limited changes, OAL approval pending as of 23 September 2026; not enjoined

California law requiring US-based companies with more than $1 billion in annual revenue that do business in the state to report Scope 1 and 2 emissions each year from 2026 and Scope 3 from 2027, with third-party assurance phased in. CARB adopted an initial regulation covering applicability, fees and the first deadline in February 2026 and is drafting a second rule for 2027 reporting onward. For 2026 only, CARB guidance issued 1 September 2026 lets companies submit existing Scope 1 and 2 data or a statement that data were not collected, and CARB will use enforcement discretion for good-faith first-year filings.

Enforcement: Mandatory
Effective date: First Scope 1 and 2 reports due 10 November 2026 (CARB's proposed deferral from 10 August 2026, pending OAL approval); Scope 3 reporting from 2027; CARB proposes limited assurance of Scope 1 and 2 starting with 2027 reports
Covered entities: US-based business entities with total annual revenue above $1 billion that do business in California. CARB's proposed 15-day changes assess coverage entity by entity and let a parent file consolidated reports and pay fees for covered subsidiaries.

Primary source ↗Verified 2026-09-23

US-CA-EPR

SB 54 Plastic Pollution Prevention and Packaging Producer Responsibility Act (2022); paint stewardship AB 1343; mattress stewardship AB 2308; carpet stewardship AB 2398; battery stewardship AB 2440; sharps; textiles SB 707 (2024)

United States (California) · California Department of Resources Recycling and Recovery (CalRecycle), which oversees the packaging, textile, battery, mattress, carpet, paint, and pharmaceutical and sharps stewardship programs

In force; SB 54 permanent regulations effective 1 May 2026; PRO program plan under review; federal and state court challenges pending

California runs the most extensive set of state EPR laws in the US, anchored by SB 54, which makes producers of single-use packaging and plastic food service ware fund collection, recycling and source reduction through Circular Action Alliance as the state's PRO. CAA filed its program plan in June 2026 and CalRecycle must act on it by 1 January 2027. Separate laws cover paint, mattresses, carpet, batteries, pharmaceuticals and sharps, and textiles (SB 707, with Landbell USA approved as the PRO in March 2026).

Enforcement: Mandatory
Effective date: SB 54 signed 30 June 2022; permanent regulations effective 1 May 2026; Circular Action Alliance submitted the program plan 15 June 2026, with CalRecycle approval and program start due on or before 1 January 2027; first Plastic Pollution Mitigation Fund payment due 1 March 2027; full recyclability and 65% recycling rate by 1 January 2032; textiles (SB 707): producers had to join the PRO by 1 July 2026, PRO needs assessment due March 2027, approved plan required by July 2030 and full implementation in 2031
Covered entities: Producers of single-use packaging and plastic food service ware sold in California; paint, mattress, carpet, battery and battery-embedded product, pharmaceutical and sharps, and textile producers under each product-specific stewardship law

Primary source ↗Verified 2026-09-23