This court challenge to the bills was filed in January 2024 by several major trade groups and business organizations, led by the U.S. and California Chambers of Commerce.
On November 18, 2025, the U.S. Court of Appeals for the Ninth Circuit issued an injunction temporarily halting the implementation of California’s SB 261, the Climate-Related Financial Risk Act, just weeks before the law’s first mandated disclosures on January 1, 2026. The court declined to stay California’s companion climate emissions disclosure bill, the Climate Corporate Data Accountability Act (SB 253), due to that bill’s less immediately pressing compliance deadline of August 2026.
Background on California Climate Disclosure Laws
As we have discussed in previous posts, California enacted two comprehensive climate disclosure laws in 2023. The Climate Corporate Data Accountability Act (SB 253) and the Climate-Related Financial Risk Act (SB 261) impose greenhouse gas emissions and climate-related financial risk reporting requirements that apply to thousands of public and private companies formed under U.S. law and “doing business in California.” The California Air Resources Board (CARB) has released a preliminary list of companies it believes may be subject to the state’s new climate disclosure regime.
Reprinted courtesy of Michael S. McDonough, Pillsbury and Karen Eskander, Pillsbury
Mr. McDonough may be contacted at michael.mcdonough@pillsburylaw.com
Ms. Eskander may be contacted at karen.eskander@pillsburylaw.com