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California Air Resources Board publishes Draft SB 261 Guidance

A wave breaks in the Pacific Ocean as luxury homes line the coast of Crescent Bay Beach on a clear, summer day on September 5, 2025, in Laguna Beach, California.
Photo: Kevin Carter/Getty Images

Michael R. Littenberg | Ropes & Gray, Marc Rotter | Ropes & Gray, Peter Witschi | Ropes & Gray+1

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This disclosure mandate will require subject companies to publish their first biennial climate-related financial risk reports by January 1, 2026.

On September 2, the California Air Resources Board (CARB) released draft guidance on the Climate‐Related Financial Risk Act (Health & Safety Code Section 38533/Senate Bill 261).

The bulk of the draft guidance consists of a checklist to be used in preparing the climate risk report required by Section 38533. The draft

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