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Early observations from voluntary climate risk reports submitted to the California Air Resources Board

May 21, 2026

As climate disclosure regulations gain momentum worldwide, many companies are being asked to report climate-related financial risks and greenhouse gas emissions. While most are familiar with financial reporting, these new regulations require them to collect, analyze and disclose nonfinancial data—often for the first time.

Over the past few years, PwC has tracked how companies are responding to requirements in the EU. We are now turning to California’s SB 261, which focuses on disclosures of climate-related financial risks and related mitigation measures. Although the California Air Resources Board (CARB) recently approved regulations to operationalize the state’s climate disclosure laws, enforcement is currently paused under a court-ordered stay.

Until the case is resolved, CARB has indicated companies may submit reports voluntarily. As of January 30, 2026, about 94 submissions appeared on CARB’s public docket. While these submissions may not reflect how companies would respond absent the injunction, they still offer useful insight into emerging disclosure practices under SB 261.

Read our analysis of this initial voluntary reporting.

California SB 261

Sustainability watch

Here are the topics we have our eyes on. More coming soon!

  • Challenges of building new nuclear energy generation
  • Water scarcity
  • Reverifying sustainability targets
  • Physical climate risk
  • Using AI for emissions reporting
  • Agentic commerce
  • Large energy user survey

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