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Enforcement of California SB 261 Preliminarily Enjoined: Implications for Companies (additional memos)

By Randi Morrison posted 20 hours ago

  

Further to yesterday's post (copied and pasted below), additional memos are here: Hogan Lovells | Sullivan & Cromwell | Wilson Sonsini

These and additional memos will be posted on our Climate Risk & Disclosure page under Memos (Regulatory).

Enforcement of California SB 261 Preliminarily Enjoined: Implications for Companies

Randi Morrison

Nov 19, 2025 5:35 PM

Randi Morrison

Further to the note in today's Society Alert regarding the Ninth Circuit's preliminary injunction of the enforcement of California's SB 261 (as amended by SB 219) (climate-related financial risk reporting) that was published during CARB's third virtual public workshop yesterday (which the Society attended), see these memos from  Ropes & Gray and Simpson Thacher with additional detail and guidance for in-scope companies that have been preparing for compliance pursuant to the January 1, 2026, statutory deadline. Watch this space for additional  commentary and guidance on this development.  

   See also "U.S. Court Pauses Implementation of California Climate Reporting Law" (ESG Today).



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Ms. Randi Morrison
General Counsel & Chief Knowledge Officer
Society for Corporate Governance
New York NY
(212) 681-2001
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