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
Brazilian National Council of Justice Recommends Parameters for Quantifying the Climate Impact of Environmental Damages
The Brazilian National Council of Justice (CNJ) has recently issued Recommendation No. 156/2024, advising all branches of the Brazilian Judiciary and judges to adopt the second scope of the CNJ’s Protocol for Judging Environmental Lawsuits (Protocol). This second scope provides guidelines for quantifying the impact of environmental damages on climate change. In 2023, the CNJ
COP-29: Progress in the Operationalization of the International Carbon Credit Market
On November 11, 2024, one of the first substantive outcomes of the 29th Session of the UN Conference of the Parties to the UN Framework Convention on Climate Change (COP29) was approved. The President of COP19 introduced a draft decision of the Conference of the Parties Serving as the Meeting of the Parties to the
Brazil Enacts New Framework for Carbon Capture and Storage
On October 8 2024, Brazil enacted Federal Law No. 14,993/2024, which stems from Bill No. 528/2020, the “Fuels of the Future Bill.” The new law, which addresses several matters related to decarbonization, provides for the regulation and inspection of activities involving the capture and geological storage of carbon dioxide, also known as CCS (Carbon Capture
Brazil’s Attorney General Files Climate Lawsuit to Protect Conservation Unit
On September 16, 2024, Brazil’s Attorney General filed a lawsuit seeking compensation for climate damage resulting from environmental infractions allegedly perpetrated by livestock farmers inside a Conservation Unit, more specifically the Jamanxim National Park, located in the Amazon Rainforest.
In Brazil, a Conservation Unit is a type of specially protected area, legally established by public
Governor Newsom Proposes Delay of California Climate Disclosure Laws
On July 15, 2024, Governor Gavin Newsom proposed amendments that would, among other things, delay initial reporting deadlines for two of California’s recently enacted climate-related disclosure laws by two years.
Governor Newsom signed the two bills, Climate Corporate Data Accountability Act (California Senate Bill 253 (SB-253)), relating to greenhouse gas (GHG) emissions disclosures, and the
VOLUNTARY CARBON MARKETS
- High-integrity VCMs, as well as carbon credit markets more broadly, have the potential to support decarbonization efforts within the United
SUSTAINABILITY COORDINATORS: A TRANSATLANTIC COMPARISON
On April 24, 2024, the Loan Market Association (LMA) published its Sustainability Coordinator Letter. The publication of the LMA’s letter follows the LSTA’s February 2023 publication of its own Sustainability Structuring Agent Engagement Agreement Inserts. This Legal Update contains a comparative analysis of the LMA and LSTA’s documents, notes key similarities and differences between the