California’s climate disclosure regime continues to evolve rapidly, with significant regulatory developments, implementation guidance, and litigation affecting the compliance landscape for companies doing business in California. There have been several important developments regarding implementation of California’s landmark climate-disclosure statutes—SB 253 (the “Climate Corporate Data Accountability Act”) and SB 261 (the “Climate-Related Financial Risk Act”), together
California Climate Disclosure Law SB 261 Implementation Halted: Ninth Circuit Grants Injunction Pending Appeal
We know our clients have been following California’s climate-disclosure laws closely – including the timing of effectiveness and the various legal challenges. This update relates to a new Ninth Circuit ruling that has effectively hit “pause” on one key pillar of California’s climate-disclosure package.
On November 18, 2025, the Ninth Circuit Court granted a partial
CARB Delays Rulemaking on California Climate Disclosure Laws—But Reporting Deadlines Stand Firm in Light of New Challenge
This update covers information regarding the California Air Resources Board (CARB) rulemaking delay for California’s climate disclosure laws, SB 253 and SB 261, as well as additional new litigation challenging the constitutionality of these laws. The bottom line for companies is that despite the rulemaking delays and ongoing litigation, the laws remain valid and in
US APPEALS COURT TEMPORARILY HALTS SEC’S CLIMATE CHANGE DISCLOSURE RULES
On March 15, 2024, the US Court of Appeals for the Fifth Circuit granted an administrative stay of the climate-related disclosure rules recently adopted by the US Securities and Exchange Commission (the “SEC”). The SEC rules require public companies to provide information about climate-related risks that could significantly impact their business or financial statements. See
QUICK REFERENCE CHART ON KEY GLOBAL CLIMATE-RELATED DISCLOSURE RULES
Climate disclosure regulations are among the most significant and complex challenges faced by companies and boards, with a variety of requirements emanating from numerous governmental authorities and non-governmental organizations (NGOs) in recent years. Mayer Brown lawyers from around the world produced a White Paper on Global Climate Change Disclosure Initiatives and Board Corporate Governance Considerations
GLOBAL CLIMATE CHANGE DISCLOSURE INITIATIVES AND BOARD CORPORATE GOVERNANCE CONSIDERATIONS
Climate disclosure regulations are among the most significant and complex challenges faced by companies and boards, with a variety of requirements emanating this past year from numerous governmental authorities and non-governmental organizations. This white paper—an expanded version of a white paper we published in January—discusses key features and differences of a dozen authorities, followed by
LAWSUIT CHALLENGES RECENT CALIFORNIA CLIMATE DISCLOSURE LAWS
A new lawsuit filed by several business interest groups seeks to overturn two recent California laws relating to emissions disclosures (SB253) and climate-related financial risk disclosures (SB261), which would require thousands of covered companies to begin making disclosures as early as 2026. This Legal Update addresses the main arguments of the lawsuit, the initial reaction
Offshore Wind: New California Law Aims to Simplify and Expedite Offshore Wind Energy Development
California recently enacted two laws—the Offshore Wind Expediting Act (SB 286) and the California Offshore Wind Advancement Act (AB 3)—to accelerate the development of offshore wind energy that could have significant implications for the industry and its stakeholders. The new laws aim to streamline the offshore wind permitting process, promote collaboration among state agencies
New California Anti-Greenwashing Law Goes Live on January 1, 2024 – What you need to know if you make certain “green” claims
A new California ”anti-greenwashing” law comes into effect on January 1, 2024. The law – called the Voluntary Carbon Market Disclosures Act (AB 1305) (VCMDA) – casts a wide net over companies participating in the California voluntary carbon market or that make certain “green” claims within California. The VCMDA applies regardless of revenue thresholds if
New “Climate Reporting” Laws in California – Emissions and Climate-Related Financial Risk Disclosure Required
Two new bills have been passed in California as part of a “Climate Accountability Package” that require U.S.-based companies “doing business”[1] in California to make disclosures about their emissions and climate-related financial risks. These are (a) the Climate Corporate Data Accountability Act (California Senate Bill 253 (SB-253)) and (b) the Climate-Related Financial Risk Act (California Senate Bill 261 (SB-261)). The laws remain subject to approval by the California Governor (who has until October 14, 2023, to sign or veto them).
To assist companies in preparing for these new climate-related disclosure requirements, we have provided a summary of some of the key requirements below.
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