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As noted in prior Society Alerts (see here and here), companies may submit climate-related financial risk reports on a voluntary basis while litigation over SB 261 remains pending. A recent DLA Piper memo reviews publicly available reports posted to CARB’s website as of February 19 and identifies several early trends in voluntary disclosures:

• Who is reporting? Early filers span industries and include both public and private companies.
• Frameworks used: Disclosures show strong convergence around TCFD (used by ~88% of companies), supplemented by ISSB or other schemes, reflecting efforts to align reporting with existing global disclosure frameworks and standards. That said, nearly three-quarters of reports were SB 261-specific rather than a link to an existing report.
• Climate-related risk: Nearly all companies identified material risks—most commonly transition, physical, and supply chain risks, reportedly indicating widespread acknowledgment among filers of climate change as a financially material risk.
• Climate-related metrics and targets: About two-thirds of companies disclosed metrics and targets (often emissions-related), suggesting their leveraging of existing quantitative climate reporting practices, while others are still developing them.
• GHG disclosure: Although not required, approximately 79% of companies reported GHG emissions, indicating the foundational nature of emissions data in relation to many companies’ climate-related financial risk analysis.
• Climate-related opportunities: Approximately 92% of companies disclosed climate-related opportunities —most often tied to transition-aligned products and services, operational efficiencies, resilience, and long-term climate-related growth —reflecting alignment with TCFD principles.
• Climate governance: Early disclosures emphasize governance structures and oversight, reinforcing a principles-based, TCFD-driven approach that highlights board and management roles in climate risk management.

These early submissions suggest that, even in a voluntary disclosure environment, companies are grounding SB 261 reporting in established global frameworks and using existing disclosures as a foundation.