On October 14, 2025, the California Air Resources Board (CARB) quietly announced it was delaying its release of a proposed rulemaking on California’s climate laws.

While the rules were originally mandated by January 1, 2025, a statutory amendment in 2024 pushed that deadline to July 1, 2025. As that date came and went without any proposed rulemaking, CARB announced its intent in a public workshop on August 21, 2025, to publish proposed rules on October 14. On that date, CARB instead posted a sentence on the “resources” section of its website that read, “CARB is proposing an updated timeline for bringing the initial rulemaking (including the fee-related provisions) to the board in Q1 2026.”

While the online message made clear that CARB would not in fact be releasing proposed rules on its target date of October 14, the message is unclear regarding CARB’s new timeline. Does CARB now intend to propose rules in Q1 2026 or will CARB introduce rules later in 2025 and propose them to the board in Q1 2026? The reference to “initial” rulemaking also raises questions — does CARB plan to roll out rules in phases?

Senate Bill (SB) 253, the Climate Corporate Data Accountability Act, which will require public and private companies that do business in California and with revenues in excess of $1 billion to publish annual reports disclosing their greenhouse gas (GHG) emissions, does not apply to companies directly, but instead directs CARB to adopt regulations to implement the law’s requirements. While CARB staff floated a June 30, 2026, compliance date for the first such report, with no rules to implement the law, no report is required. Nonetheless, companies potentially covered by SB 253’s disclosure requirements are concerned that CARB will ultimately release a rule that leaves insufficient time to digest the rule and comply.

On the other hand, SB 261, the Climate-Related Financial Risk Act,which requires public and private companies that do business in California and with revenues in excess of $500 million to report their material climate-related financial risks on their own websites by January 1, 2026, is self-implementing. However, without implementing regulations, CARB cannot collect the fees mandated by the law to fund the program. Nor can it bring an enforcement action; the law specifically directs CARB to adopt regulations that would authorize it to seek penalties from companies that fail to report or publish insufficient reports. Furthermore, some entities potentially covered by SB 261 would like CARB to issue regulations before the January 1, 2026 deadline providing more clarity regarding which entities must submit disclosures and what those disclosures must contain.

CARB’s rulemaking process to date has been erratic and haphazard. The agency has missed both statutory deadlines and its own anticipated deadlines, while also releasing “guidance” that has sown confusion among potentially regulated entities. With the January 1, 2026 compliance deadline for SB 261 disclosures rapidly approaching, it is highly unlikely that CARB will be providing needed regulatory clarity, even in the form of proposed regulations, in time to help companies that must determine whether they are required to make these disclosures and what they must disclose. While there are currently no proposed deadlines for SB 253 GHG reporting absent implementing regulations, CARB’s rulemaking delay will only continue to compress the time available to companies to prepare for reports of their 2025 GHG emissions sometime in 2026.