On September 2, 2025, the California Air Resources Board (ARB) posted a draft checklist with information to help targeted “covered entities” comply with requirements to provide “Climate Related Financial Risk Disclosure.” These Disclosures are required beginning January 1, 2026, in compliance with state legislation (SB 261 (Stern)) enacted in 2023 (which I wrote about HERE), and amended in 2024 (SB 219 (Wiener); I wrote about it HERE). The remainder of this note summarizes SB 261 and ARB’s draft checklist.
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Tags:
sustainability,
ARB,
compliance,
Environmental Regulations,
Corporate Sustainability,
Climate Disclosure,
ESG Reporting,
SB261,
CARB,
Corporate Risk
In 1987, California adopted the Air Toxics “Hot Spots” Information and Assessment Act, responding to increasing concern over toxics in the air (AB 2588 (Connelly, Sterling)). This law complements California’s enforcement of national requirements governing stationary source emissions of air toxics. The federal Clean Air Act (CAA) required the U.S. Environmental Protection Agency (EPA) to establish and maintain a list of air toxics, named as Hazardous Air Pollutants (HAPs), and to set emissions standards (National Emissions Standards for Hazardous Air Pollutants (NESHAPs) for many HAP emission sources; California incorporates HAP/NESHAP requirements into the state’s Toxic Air Contaminant (TAC) / Airborne Toxic Control Measure (ATCM) program. (I discussed these requirements HERE).
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Tags:
OSHA,
CAA,
Cal/OSHA,
California,
Air Toxics,
NESHAPs,
TAC,
ATCM,
Hot Spots Act,
OEHHA,
BAAQMD,
HAPs,
ARB
