CARB Releases Checklist & List of Companies for SB 261 & SB 253

SB 261 (California’s Climate-Related Financial Risk Act) is right around the corner. Are you ready? As a reminder, SB 261 requires all business entities engaged in business in California — with annual revenues over $500M — to submit biennial disclosures regarding climate-related financial risk (CRFR). The initial CRFR report must be submitted to the CARB public docket (open December 1, 2025 — January 1, 2026) and posted on the company website by January 1, 2026. Scroll below for critical information about the CARB checklist & guidance, and the preliminary list of companies just released on September 29th, 2025.

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Checklist:

On September 2nd, 2025, CARB released a draft checklist for SB 261 for the initial climate-related financial risk report that must be posted on a company’s website by January 1, 2026. The checklist includes minimum disclosures, clarifications, key links, and resources related to the frameworks (e.g. TCFD, IFRS2 ) that companies may use to meet reporting requirements. NOTE: CARB has noted that including Scope 1,2, and 3 emission reporting is not a minimum requirement for initial SB 261 reporting on January 1, 2026.

Preliminary Company List:

Is your company on the CARB list? On September 29th, CARB published a preliminary its published its preliminary list of thousands of entities that may be subject to upcoming reporting requirements under either or both SB 253, which covers GHG emissions, and SB 261, which covers climate-related financial risks. CARB has ackn owleged that the list may be incomplete and has posted a survey to collect more information about additional entites that may be subject to regulations or stakeholders that might qualify for an exemption. The agency stated the following: "Each potentially-regulated entity remains responsible for compliance with statutory requirements, regardless of whether it was included in staff’s preliminary list or outreach."