California climate disclosure laws: Ninth Circuit temporarily halts SB 261 and CARB provides new guidance - White & Case LLP
The Ninth Circuit temporarily halted enforcement of California's SB 261 climate disclosure law, and CARB issued new guidance. This pause affects large private companies and public filers subject to SB 261, delaying compliance deadlines and potentially reducing penalties.
Aforeworn detected this change in the ESG & Climate Disclosure space on July 7, 2026 and published this briefing so affected operators are forewarned rather than caught off guard. It is rated High urgency. Large private companies and public filers subject to SB 261 (doing business in California with annual revenues >$1B) should confirm how it applies to their specific situation before acting. There is a time constraint attached: No immediate deadline due to the halt, but prepare for potential reinstatement within 6-12 months.. Acting after that point can mean penalties, a lapsed licence, or lost eligibility — exactly the kind of surprise Aforeworn exists to prevent. Aforeworn monitors ESG & Climate Disclosure continuously and turns every detected change into a plain-English briefing like this one, so you always know first. Forewarned is forearmed.
What changed
SB 261 enforcement is temporarily halted by the Ninth Circuit; CARB provided new guidance on compliance expectations.
Who it affects
Large private companies and public filers subject to SB 261 (doing business in California with annual revenues >$1B)
What you must do
Monitor court developments and CARB guidance; pause any immediate compliance spending but continue preparing for eventual implementation.
Deadline
No immediate deadline due to the halt, but prepare for potential reinstatement within 6-12 months.
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- California climate disclosure laws: CARB issues draft regulations - White & Case LLP
- CARB Delays Enforcement of California’s Climate-Related Financial Risk Report Law (SB 261) and Issues New Guidance on Climate Disclosure Requirements in SB 261 and SB 253 - Crowell & Moring LLP
- Federal appeals court halts implementation of California’s climate law SB 261 - ESG Dive
- CARB delays emissions reporting deadline by 3 months - ESG Dive
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