On November 18, 2025, the Ninth Circuit Court of Appeals ruled to temporarily stay implementation of California SB 261, the state’s corporate climate-related financial risk reporting law, while an appeal is pending related to an industry group-led challenge to the law. In the short ruling, the Ninth Circuit denied the motion to stay implementation of the companion bill, the Climate Corporate Data Accountability Act.

As the 2026 proxy season approaches, companies should be mindful of developments in required executive compensation disclosures and related issues that may arise as they prepare proxy statements. This alert surveys key developments and provides specific action items for companies to consider.

In an address delivered on November 12, 2025 at the Federal Reserve Bank of Philadelphia, Securities and Exchange Commission (SEC or Commission) Chairman Paul S. Atkins outlined the next phase of the SEC’s “Project Crypto,” advocating for clarity and fairness in the regulation of digital assets.