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.

On September 27, 2024, California Governor Gavin Newsom signed into law amendments to California’s first-in-the-nation greenhouse gas emissions disclosure and climate-related financial risk reporting bills. The amendments did not delay the reporting deadlines applicable to reporting entities, and companies should take action now to ensure they will be ready to report on 2025 emissions and risks starting in 2026.

As expected, a flurry of briefs from state attorneys general, the Securities and Exchange Commission (the SEC), and amici curiae have been filed with the 8th Circuit Court of Appeals as the climate rulemaking case makes its way through the courts.