Unlike the proposed rollback of EPA GHG reporting requirements, some states are going forward with their disclosure regulations. A federal judge in California refused to halt the implementation of California's climate disclosure laws, which impose several reporting deadlines, the first of which is January 1, 2026 (SB 261, climate-related financial risk reports).

In 2023, California passed two laws—SB 253, the Climate Corporate Data Accountability Act; and SB 261, the Climate-Related Financial Risk Act—that will require large public and privately-held entities doing business in California to comply with new and comprehensive disclosure requirements regarding their direct and indirect greenhouse gas emissions and their climate-related financial risks. California subsequently passed SB 219, which updated certain deadlines and requirements of the laws.

The U.S. Chamber of Commerce, the California Chamber of Commerce, and other business trade associations sued CARB last year alleging that the laws unlawfully compel speech in violation of companies' First Amendment rights. On August 13, 2025, the U.S. District Court for the Central District of California declined to grant a preliminary injunction which would have suspended the requirement to comply with the laws pending the outcome of the litigation. Thus, unless an appeal is successful, the laws will go into effect as written.

But CARB still has not provided the guidance required by statute to advise companies how to meet the reporting requirements. CARB was directed by law to publish regulations by July 2025 but has not met this statutory deadline. In July, CARB stated it "is committed to developing a regulation by the end of the year." The regulations are expected to provide guidance on compliance, future deadlines, and enforcement standards.

On August 21, 2025, CARB held a virtual public workshop to provide additional guidance regarding the Climate Disclosure Laws. Of note, CARB outlined its regulatory process, including providing expected timelines. It also offered clarifications with respect to certain of the Climate Disclosure Laws' definitions and how entities can disclose climate-related risks.

For the first round of reporting due January 1, 2026 for entities covered by SB 261, CARB said at the workshop that it will accept "good faith efforts." In other words, CARB will accept reports that companies prepared to the best of their knowledge and from the use of the best available data. With respect to SB 253 reports, which CARB proposes to be due on June 30, 2026, CARB expects reporting entities to obtain assurance (or verification) from an independent third-party provider for their Scope 1 and 2 emissions at a "limited-assurance" level.

Additional information on compliance is available here.