CARB will open a public docket on December 1, 2025, for SB 261 climate-related financial risk reports, which will remain accessible until July 1, 2026. CARB has reiterated that SB 261 does not mandate the disclosure of information that falls outside of the definition of climate-related financial risks, and the law allows some flexibility in choosing a reporting framework. To provide a phase-in period for reporting, CARB has stated that initial reports may be based on the best available information, including from fiscal years 2023/2024 or 2024/2025. CARB held a second public workshop to support the development of SB 253 and SB 261 on August 21, 2025. These laws are also the subject of ongoing litigation brought by the U.S. Chamber of Commerce and others, and they may find themselves jeopardized by President Donald Trump's executive order titled "Protecting American Energy From State Overreach." Shook attorneys are closely following developments and updates on SB 253 and SB 261.