On July 9, 2025, the California Air Resources Board (CARB) released a set of Frequently Asked Questions regarding California’s Climate Corporate Data Accountability Act (SB 253) and the Climate-Related Financial Risk Act (SB 261) (each bill as amended by Senate Bill 219).  While the FAQs do not carry the force of law, they provide some useful information and answer a few nagging questions for companies preparing for the upcoming reporting deadlines, as summarized below.

• Determining Revenue: As suggested during CARB’s public workshop earlier this year, the initial staff concept for determining “total revenue” for a company is defined as gross receipts as set forth in California Revenue and Taxation Code § 25120(f)(2). CARB is seeking public feedback on this proposed definition
• Doing Business in California: As suggested during CARB’s public workshop earlier this year, the initial staff concept for “doing business in California” is based on the Franchise Tax Board definition. CARB is seeking public feedback on this proposed definition, including whether CARB should consider exemptions for certain circumstances.
• Public Docket for SB 261 Reports:  On December 1, 2025, CARB will post a public docket for covered entities to post the location of the public link to their first climate-related financial risk report. The docket will remain open through July 1, 2026, serving as a centralized location for public access to all submitted reports. This guidance is intended to assist companies with initial planning for January 1, 2026. 
• Time Period Covered by the First SB 261 Report: The FAQs indicate that initial climate-related financial risk reports submitted by January 1, 2026 may be based on the company’s best available information, including information from fiscal years 2023/2024 or 2024/2025, depending on the organization.

According to the FAQs, CARB is committed to developing regulations by the end of the year and will include additional opportunities for public input over the summer. The FAQs also provide this link for stakeholders to sign up for future emails on this topic.