Widely understood and communicated as requiring compliant disclosures as of the January 1, 2024, effective date, it now appears that the intended compliance deadline associated with California’s Voluntary Carbon Market Disclosures Act (AB 1305) (we previously reported on here) is January 1, 2025. The bill’s sponsor, Assemblymember Jesse Gabriel, has submitted a letter of legislative intent to the Chief Clerk of the California state Assembly to that effect and indicating that he intends to submit a formal letter to the Assembly Daily Journal when the State Assembly reconvenes January 3, 2024. According to sources cited in this memo from Ropes & Gray, the Assembly Daily Journal is a known source of helping to determine legislative intent in the face of ambiguity.
The absence of an express disclosure deadline is among a number of ambiguities or areas of uncertainty in the law.
Stay tuned for further updates.