California Air Resources Board

The California Air Resources Board (CARB) has opened the public docket for entities that may choose to voluntarily submit their Climate-Related Financial Risk Report, under Senate Bill (SB) 261 (Stern, Stats. 2023, ch. 383, codified in Health and Safety Code section 38533). 

On November 18, 2025, the Ninth Circuit Court of Appeals issued an order in Chamber of Commerce v. Sanchez, Case No. 25-5327 (9th Cir. 2025), granting an injunction against the enforcement of SB 261 during the pendency of appellate proceedings in that matter. In light of the Court’s order, CARB will not enforce Health and Safety Code section 38533 against covered entities for failing to post and submit reports by the January 1, 2026, statutory deadline. Please see CARB’s advisory with guidance to stakeholders available here. 

Instructions for submission:

Entities choosing to voluntarily submit their reports at this time are asked to include the following information:  

1. Company statement on official letterhead 

   • For entities submitting a consolidated report (for parent and subsidiary/subsidiaries), please specify the list of subsidiaries included, as applicable. 

   • Please use the following file naming convention: "CompanyName_Statement_date".  

2. Climate-Related Financial Risk Report (Link to the website) 

   • For entities choosing to voluntarily submit a report at this time, the report should be posted on the company’s own website and publicly accessible. 

   • Entities can submit a link to the website containing the report in the “Message” field on the public docket submittal page. 

For more guidance regarding reporting under Health and Safety Code section 38583, refer to the December 2025 enforcement notice on SB 261, SB 261 draft checklist and FAQ.