The State of California follows a structured process for adopting regulations that is governed by the Administrative Procedure Act (APA). The objective of the APA process is to ensure that regulations are developed with public input, legal clarity and accountability.
As part of Step 1 of the APA process, on May 29 the California Air Resources Board (CARB) held its first public workshop to discuss the development of regulations that will underpin SB-253 and SB-261.
CARB’s intention is to hold a series of workshops throughout the remainder of 2025 � listening to stakeholder feedback and sharing its thinking as it develops draft regulations. We’ll bring you up-to-date news and insights as they develop.
Scroll down to read more below about CARB’s first workshop on May 29.
Here you’ll find key information to help you navigate the evolving landscape of the California climate laws. Use the jump links below to quickly access specific topics: a fast overview of the climate laws, details about the California legislative process under the APA, and key points covering the latest CARB developments.
Click on the links to understand what each of the three climate laws cover.
The Climate Corporate Data Accountability Act, as amended by SB-219, mandates the disclosure of GHG emissions. It applies to US businesses that meet specified revenue thresholds and do business in California. The effective date for reporting is 2026 for scopes 1 and 2 and 2027 for scope 3.
The Greenhouse Gases: Climate-related Financial Risk Act, as amended by SB-219, mandates the disclosure of climate-related financial risks and measures adopted to reduce and adapt to such risks. It applies to US businesses that meet specified revenue thresholds and do business in California. The effective date for reporting is on or before January 1, 2026.
The Voluntary Carbon Market Disclosures Act mandates disclosures about voluntary carbon offsets and emissions reduction claims. It applies to US and international companies that undertake specified activities in California or make certain claims. The effective date for reporting is January 1, 2024. Proposed amendment AB-2331 would change this date to July 1, 2025 but failed to pass before the end of California’s 2024 legislative session.
No delay in 2026 reporting under California climate laws
CARB set to hold multiple public workshops as it develops regulations, but 2026 reporting will not be pushed back.
Download PDFIn developing regulations, CARB will follow California’s structured process for adopting regulations set forth in the Administrative Procedure Act (APA). The objective of the APA process is to ensure that regulations are developed with public input, legal clarity and accountability.
CARB has one year from the date of releasing proposed regulations for public comment (Notice of Proposed Action) through to final approval and filing.
For an overview of the APA process, click on the steps below.
-ÌýAuthority. CARB must have legal authority (under SB-253 and SB-261) to adopt the regulations.
-ÌýReference. The regulations must properly cite the relevant statutes or other legal provisions.
-ÌýConsistency. The regulations must not conflict with existing laws or other regulations adopted by CARB and should align with the broader legal and regulatory framework.
-ÌýClarity. The regulations must be written so that they are easily understood by those who are directly affected. This includes using plain language, avoiding jargon and ensuring the regulations are internally consistent and unambiguous.
-ÌýNon-duplication. The regulations must not in effect duplicate any other state law or regulation.
-ÌýNecessity. The regulations must be essential to carry out the purpose of the law.
At the workshop, it was repeatedly emphasized that the reporting dates cannot be changed � despite delays in developing the underlying regulations � because they are in the laws. This means that the first reporting under SB-261 (climate risks) is due by January 1, 2026, and the first reporting under SB-253 (GHG emissions) is due in 2026.
To facilitate reporting before regulations are final, CARB will not seek to impose penalties for ‘good faith efforts� � relying on the relief in the laws and the CARB enforcement notice issued in December 2024. Read more in our Hot Topic (see link below). In addition, CARB staff indicated they will keep lines of communication open during 2025 to provide their latest thinking.
Notwithstanding the enforcement relief in the first year, CARB acknowledges that there are a significant number of interpretative questions that remain unresolved. Through a series of workshops to be held in 2025, it will work through the issues, focusing on scoping first. In the May workshop, CARB staff revealed tentative thinking that ‘doing business in California� would be based on the California Revenue and Taxation Code. However, CARB remains open to discussion and encouraged constituents to express their views in writing.
No delay in 2026 reporting under California climate laws
CARB set to hold multiple public workshops as it develops regulations, but 2026 reporting will not be pushed back.
Download PDF
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