California is forging a path for climate disclosure with its series of related legal frameworks requiring covered entities to disclose climate-related information, supporting documentation for certain net zero claims and financial risk frameworks.
In October 2023, California became the first state to enact such broad climate disclosure legislation, with the passage of the:
Climate Corporate Data Accountability Act (SB 253),
Climate-Related Financial Risk Act (SB 261), and
California’s Voluntary Carbon Market Disclosures Act (AB 1305).
Entities covered by these three programs generally include those that do business in the state of California and either (1) make certain climate related claims about the business, its products, etc.; (2) market and/or purchase certain voluntary carbon offsets; and/or (3) meet certain monetary thresholds (for purposes of SB 253 and SB 261).
California is forging a path for climate disclosure with its series of related legal frameworks requiring covered entities to disclose climate-related information, supporting documentation for certain net zero claims and financial risk frameworks.
In October 2023, California became the first state to enact such broad climate disclosure legislation, with the passage of the:
Climate-Related Financial Risk Act (SB 261),
Climate Corporate Data Accountability Act (SB 253), and
California’s Voluntary Carbon Market Disclosures Act (AB 1305).
Entities covered by these three programs generally include those that do business in the state of California and either (1) make certain climate related claims about the business, its products, etc.; (2) market and/or purchase certain voluntary carbon offsets; and/or (3) meet certain monetary thresholds (for purposes of SB 253 and SB 261).
With compliance deadlines already in place or approaching quickly, implementation has been challenging for industry. The California Air Resources Board (CARB) is responsible for promulgating regulations associated with the three statutory programs, but has yet to do so. AB 1305 has already gone into effect, with its first deadline occurring as of January 1, 2025. SB 253 and SB 261 have deadlines starting in 2026. Like AB 1305, SB 261’s climate-related financial risk disclosure requirement does not depend on CARB completing its rulemaking prior to when the first reports are due on January 1, 2026. However, SB 253 differs from the other two in that no reporting obligations are imposed without CARB’s adoption of implementing regulations. Regulated entities needs to be prepared to comply while remaining flexible given pending publication of regulations in December.
To assist, this three part series provides a high-level guide on the three programs, including the applicability, the program’s coverage, steps for compliance, timing and other miscellaneous information based on current regulatory guidance. Here we focus on disclosure under California’s Climate Corporate Data Accountability Act (SB 253), which has an anticipated reporting deadline of July 30, 2026 (pending promulgation of implementing regulations).
California is forging a path for climate disclosure with its series of related legal frameworks requiring covered entities to disclose climate-related information, supporting documentation for certain net zero claims and financial risk frameworks.
In October 2023, California became the first state to enact such broad climate disclosure legislation, with the passage of the:
Climate-Related Financial Risk Act (SB 261),
Climate Corporate Data Accountability Act (SB 253), and
California’s Voluntary Carbon Market Disclosures Act (AB 1305).
Entities covered by these three programs generally include those that do business in the state of California and either (1) make certain climate related claims about the business, its products, etc.; (2) market and/or purchase certain voluntary carbon offsets; and/or (3) meet certain monetary thresholds (for purposes of SB 253 and SB 261).
With compliance deadlines already in place or approaching quickly, implementation has been challenging for industry. The California Air Resources Board (CARB) is responsible for promulgating regulations associated with the three statutory programs, but has yet to do so. AB 1305 has already gone into effect, with its first deadline occurring as of January 1, 2025. SB 253 and SB 261 have deadlines starting in 2026. Like AB 1305, SB 261’s climate-related financial risk disclosure requirement does not depend on CARB completing its rulemaking prior to when the first reports are due on January 1, 2026. However, SB 253 differs from the other two in that no reporting obligations are imposed without CARB’s adoption of implementing regulations. Regulated entities needs to be prepared to comply while remaining flexible given pending publication of regulations in December.
To assist, this three part series provides a high-level guide on the three programs, including the applicability, the program’s coverage, steps for compliance, timing and other miscellaneous information based on current regulatory guidance. Here we focus on disclosure under California’s Climate-Related Financial Risks Act, SB 261, which has an initial compliance deadline of January 1, 2026.
On 26 August 2025, the Department for Environment, Food and Rural Affairs (DEFRA) launched a consultation to reform how industrial activities are regulated in England. DEFRA is also working alongside Scotland, Wales and Northern Ireland, so similar changes are likely to take place in those administrations. The consultation excludes waste operations, mining waste operations, radioactive substances activities, water discharge activities, groundwater activities and flood risk activities from reform.
It focuses on industrial emission regulation; including installations, medium combustion plants and specified generators, as well a small waste incineration plants, solvent emission activities, Part B mobile plants and mobile medium combustion plants. These reforms are motivated by the government’s push for a net zero transition and circular economy ambitions the industry is likely to move away from fossil fuel to low carbon alternatives, making the current permitting system less fit for purpose.
We set out below the main strategic goals of the proposed reforms.
The Health and Safety Executive (HSE) has published its annual on work-related fatal injury statistics. In the period April 2024 to March 2025, there were a total of 124 worker deaths, down 14 from the previous year. The most common causes of work-related fatal injury were fall from height, being struck by a moving object and being trapped by something collapsing or overturning, accounting for 60% of all fatal injuries. Construction, agriculture, forestry and fishing accounted for the highest number of deaths across all industries.
Comparatively, nonfatal injuries differ markedly to fatal injuries. Falling from height, as the most common fatal injury, only accounted for 8% of nonfatal injuries. Slips, trips or falls on the same level, and injury while handling, lifting or carrying, accounted for almost half of all employer-reported nonfatal injuries, yet the same two accident types only accounted for 1% of fatal injuries to workers.
On 16 September 2025, the European Commission published its Simplification Omnibus for Food and Feed Safety, proposing amendments to several pieces of EU legislation. The initiative aims to streamline procedures, enhance clarity and support innovation across the agri-food sector.
Despite its title, the new omnibus package is relevant not only to the agri-food sector but also to the chemical industry – particularly stakeholders involved in biocides and plant protection products. Indeed, the proposal includes suggested amendments to the following legislations:
The tyre waste exemption regime is changing in the UK, and it may impact your existing environmental permit. For example, if you have an exemption on a permitted site you may need to vary your permit, or you may lose an exemption if you benefited from more than one. You will certainly need to keep accurate records in electronic format ready for inspection by the regulator. Once these proposals are in force, you may only have three months to deal with changes to your permit.
The summer of 2025 has seen the U.S. Environmental Protection Agency (EPA) implement a significant shift in U.S. federal climate policy envisioned by the Trump Administration.
EPA proposes a reinterpretation of Section 111 of the Clean Air Act (CAA) that would require a “significant contribution finding.” As a predicate to regulation, EPA must first find that GHG emissions from fossil fuel-fired power plants contribute significantly to regulated air pollution.
EPA proposes to find that fossil fuel-fired power plants do not contribute significantly to the broader aggregation of GHG emissions in the atmosphere.
With no “significant contribution finding,” the proposed rule would thereby repeal:
The Obama Administration’s 2015 New Source Performance Standards (NSPS) (40 CFR part 60, subpart TTTT) (Adopted as part of Clean Power Plan).
The Biden Administration’s 2024 Carbon Pollution Standards (40 CFR part 60, subparts TTTTa and UUUUb).
Administrative agencies are in an era of reform. Since the US Supreme Court overturned Chevron deference, the scope of agency authority under the law has been uncertain. Simultaneously, the Trump administration has been pushing for increased efficiency within administrative agencies, issuing directives for streamlined decision making to promote the expansion of American industry. Perhaps surprising within this tumultuous backdrop, the US Supreme Court recently reached an 8-0 consensus related to administrative authority in Seven County Infrastructure Coalition v. Eagle County, 605 U.S. ____ (2025) (“Seven County”). Something of a departure from trends toward curtailing agency authority and scope, the majority holding promotes judicial deference in the context of the National Environmental Policy Act (NEPA).
