On September 24, 2025, the California Air Resources Board (CARB) released a preliminary list of 4,160 entities that may be subject to SB 253 (greenhouse gas emissions reporting) and SB 261 (climate risk disclosures). However, such list will likely be subject to significant updates as it includes over 1,000 duplicate entities, and the regulations to which such duplicated entities are subject are not consistent throughout the spreadsheet (i.e., in several places the spreadsheet states that a duplicated entity is subject to both SB 253 and SB 261 in one row and only subject to SB 261 in the next row.)

Further, there are numerous nonprofit entities included in the preliminary list, which departs from CARB’s previous proposal of covered entities. CARB notes that the list is based on entities with active filings with the California Secretary of State through March 2022 and may not be exhaustive. Companies that are included on the preliminary list or that may otherwise be subject to SB 261 should consult CARB’s draft checklist for climate related financial risk disclosures as the January 1, 2026 reporting deadline approaches.

For more information on SB 253 and SB 261, please see our initial California climate disclosure advisory and our advisory on CARB's recently published FAQs.