California regulators tasked with implementing and enforcing the state’s two landmark climate disclosure laws released draft regulatory text on December 9, 2025, providing additional insight on key issues, including initial deadlines for reporting greenhouse gas (“GHG”) emissions and details on how regulators will determine annual fees. The release of the
Continue Reading California Climate Disclosure Laws: CARB Draft Regulations Clarify Fees, Deadlines, and Applicability
Carbon Measures Coalition Signals Growing Momentum for Ledger-Based Carbon Accounting
On October 20, 2025, a coalition of nineteen leading companies in the energy, finance, and logistics sectors, launched the Carbon Measures Coalition, proposing a significant departure from established carbon accounting frameworks. The Coalition represents a prominent industry-led effort to move away from traditional inventory-based emission calculation methods toward a
Continue Reading Carbon Measures Coalition Signals Growing Momentum for Ledger-Based Carbon AccountingThe Greenhouse Gas Protocol’s Proposed Scope 2 Guidance: Key Changes and Considerations for Stakeholders
In late October, the Greenhouse Gas Protocol (“GHG Protocol”) proposed updated Scope 2 guidance for companies quantifying and reporting their greenhouse gas (“GHG”) emissions. If finalized as proposed, the guidance would have significant impacts on how companies plan their renewable energy investments and measure progress toward their climate goals. The
Continue Reading The Greenhouse Gas Protocol’s Proposed Scope 2 Guidance: Key Changes and Considerations for StakeholdersState Greenhouse Gas Reporting Programs: New York’s Proposed Mandatory Reporting Program and California’s Existing Program
While the Environmental Protection Agency (“EPA”) is proposing to amend the federal Greenhouse Gas Reporting Program (“GHGRP”) to remove reporting requirements for nearly all sources, it remains important for companies to track developments and manage their compliance obligations with existing and emerging state GHG reporting programs. Several states, such as
Continue Reading State Greenhouse Gas Reporting Programs: New York’s Proposed Mandatory Reporting Program and California’s Existing ProgramKey Takeaways From California Air Resources Board’s Public Workshop on Implementing California Climate Disclosure Laws SB 253 and SB 261
On May 29, the California Air Resources Board (“CARB”) held a virtual public workshop to discuss forthcoming regulations to implement SB 253 and SB 261, landmark California laws that require many corporate entities to disclose their greenhouse gas (“GHG”) emissions and climate-related financial risk. CARB affirmed the existing statutory deadlines
Continue Reading Key Takeaways From California Air Resources Board’s Public Workshop on Implementing California Climate Disclosure Laws SB 253 and SB 261Will the Trump Administration Clear a Path through the FERC Regulatory Thicket for the Co-Location of Data Centers with Nuclear Generation? (Part 2 of 2)
The exploding demand for energy to power hyperscaler data centers is leading to consideration of co-locating new generation (nuclear or otherwise) and data centers. As we explained in Part 1 of this blog, co-location is attractive to hyperscalers because of its potential to provide those data centers with contractually
Continue Reading Will the Trump Administration Clear a Path through the FERC Regulatory Thicket for the Co-Location of Data Centers with Nuclear Generation? (Part 2 of 2)Will the Trump Administration Clear a Path through the Nuclear Regulatory Thicket for the Co-Location of Data Centers with Nuclear Generation? (Part 1 of 2)
During his first week in office, President Trump issued Executive Orders on Removing Barriers to American Leadership in Artificial Intelligence, Declaring a National Energy Emergency, and Unleashing American Energy. On February 14, he issued another Executive Order, Establishing the National Energy Dominance Council. He has also
Continue Reading Will the Trump Administration Clear a Path through the Nuclear Regulatory Thicket for the Co-Location of Data Centers with Nuclear Generation? (Part 1 of 2)Biden Administration Releases Executive Order on AI Infrastructure
On January 14, 2025, the Biden Administration issued an Executive Order on “Advancing United States Leadership in Artificial Intelligence Infrastructure” (the “EO”), with the goals of preserving U.S. economic competitiveness and access to powerful AI models, preventing U.S. dependence on foreign infrastructure, and promoting U.S. clean energy production to power
Continue Reading Biden Administration Releases Executive Order on AI InfrastructureCalifornia Air Resources Board Solicits Stakeholder Feedback on Implementation of Climate Disclosure Laws on the Heels of New Enforcement Advisory
On Monday, December 16, the California Air Resources Board (CARB) issued an information solicitation inviting feedback on the implementation of SB 253 and SB 261. Comments are due by February 14, 2025. This information request arrives on the heels of a new CARB enforcement advisory focused on SB 253. Continue Reading California Air Resources Board Solicits Stakeholder Feedback on Implementation of Climate Disclosure Laws on the Heels of New Enforcement Advisory
California Climate Disclosure Laws’ Compliance Timeline Remains Stable While New Amendments Give State Regulator More Time and Flexibility
Companies that do business in California and meet certain revenue thresholds should continue to prepare to comply with the state’s landmark climate disclosure laws that impose reporting deadlines starting in 2026, even as a newly enacted state law gives California regulators more time and flexibility in promulgating implementing regulations.
California Governor Gavin Newsom signed Senate Bill 219 (SB 219) into law on September 27, 2024, making modest amendments to California’s two signature climate disclosure laws, SB 253 and SB 261, enacted in October 2023. SB 253, or the Climate Corporate Data Accountability Act, requires reporting entities to publicly disclose their greenhouse gas (GHG) emissions beginning in 2026 for Scope 1 and 2 emissions, and 2027 for Scope 3. SB 261, the Climate-Related Financial Risk Act, requires covered entities to publish biennial reports, beginning in January 2026, that disclose climate-related financial risk and measures adopted to reduce and adapt to that risk.Continue Reading California Climate Disclosure Laws’ Compliance Timeline Remains Stable While New Amendments Give State Regulator More Time and Flexibility