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
On September 16, 2025, the US Environmental Protection Agency (EPA) published a proposal to eliminate the vast majority of its longstanding Greenhouse Gas Reporting Program (GHGRP), which requires thousands of facilities and organizations to report annual emissions of greenhouse gases (GHGs) (40 CFR part 98). (I’ve written about this program over the years, most recently when EPA issued massive revisions in April 2024 (see HERE). The remainder of this note briefly summarizes EPA’s latest interpretation and identifies the small portion EPA proposes to retain, and the existing GHGRP.
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Tags:
EPA,
Greenhouse Gas,
Clean Air Act,
Climate,
Environmental Compliance,
EPA Regulations,
EPA Standards,
GHG Reporting,
EPA enforcement,
Climate Disclosure,
Climate Risk,
Air Quality
On March 27, 2025 the US Securities and Exchange Commission (SEC) voted to stop defending rules adopted in 2024 (during the Biden administration) that would have required selected “public companies” (i.e, listed on national securities exchanges) to provide “climate-related disclosures for investors” in their registration statements and annual reports. SEC had stayed these rules’ effectiveness after being sued by two energy companies, which were later joined by other plaintiffs as well as state and nonprofit supporters of the rules. The latest SEC decision ends the agency’s defense in that litigation.
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Tags:
SEC,
Environmental Policy,
Climate,
ESG,
Environmental Compliance,
Risk Management,
Sustainability Reporting,
Climate Disclosure,
Climate Risk
