As we previously noted, a legal challenge to California’s climate disclosure laws has made its way to the Ninth Circuit Court of Appeals, which stayed enforcement of one of the laws pending appeal.
 

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.

California’s Climate Accountability Package (the CAP) requires large public and private companies doing business in California to disclose their greenhouse gas emissions and mandates that certain companies publicly report on their climate-related financial risks and the measures they are taking to address those risks. Recent amendments have left implementation timelines largely unchanged. While legal challenges to the CAP continue and final guidance has not yet been published, companies should prepare to comply as the regulatory environment evolves.