Author Andries Verschelden

Even after California’s climate risk reporting mandate, SB 261 was paused by the courts, scores of companies reported voluntarily anyway. 

On January 1st this year, more than 4,000 companies doing business in California were expected to report their climate risks in line with the Taskforce on Climate-related Disclosures (TCFD) or International Sustainability Standards Board (ISSB) standards. But just 6 weeks before that deadline, California’s 9th Circuit Court of Appeals put a court-ordered stay on SB 261 until a decision is made in the lawsuit against it.

Given how close the decision to stall the rules was to the deadline, many of the 4,000 companies expected to report had already laid the groundwork to assess and record their climate risks. Some of those companies, 157 to be exact, have decided to report voluntarily through the California Air Resources Board’s (CARB) public docket anyway. 

While that’s only 3% of the companies believed to be in scope, it gives companies yet to report a good benchmark for what’s expected. It also provides the courts with proof that these requests for companies to report their climate risks are not a significant compliance burden, which could help the courts allow the rules to proceed unhindered.

My company Good.Lab, where I work with companies navigating exactly these requirements, conducted an analysis of these 157 reports and summarized the findings to help inform our approach to helping clients meet the requirements. Our team found it provided helpful context and wanted to share broadly to help others understand what to expect and how to prepare.

Who is Reporting? 

Across the reporters, there is an almost even split between private (55%) and public (45%) companies, with notable companies that have reported including Bridgestone, Schneider Electric, Quest Diagnostics, Valve, Roche, and Baker Tilly. 

The diversity of reporters is broad. Companies span sectors, ownership structures, and levels of sustainability maturity. That suggests climate risk disclosure is no longer confined to the largest public companies or traditional sustainability leaders.

What these initial reporters most likely have in common is that they had already done this work and wanted to share it. Those who have can now worry less about the impending court case and when they have to report. They may also gain some brand reputation among customers or investors who are tracking responses.

What Are Companies Reporting? 

Companies have the option to use either the TCFD or the ISSB standards to report.  So far, most companies are using TCFD, likely because of prior experience with it. 

These are not partial reports either. They are comprehensive, high-quality reports with an average length of 13 pages. Some companies even went beyond the rule’s requirements: 20% provided scenario analysis as part of their report, and 25% included their GHG data, a requirement of the other half of California’s climate reporting rules, the SB 253 emissions reporting rule. 

Most strikingly, fewer than 5% of companies explicitly referenced the “best efforts” compliance standard set out by CARB in the first year of the rule. In other words, most companies did not treat this as a box-checking exercise.

The actual contents of the reports are less surprising. The primary physical climate risk for the reporting companies is extreme weather events, and transitional risk is growing regulatory requirements.

RELATED ARTICLE: SEC Moves To Rescind Corporate Climate Reporting Rules

What Can Other Companies Learn From a Small Sample of SB 261 Reports?

The clearest takeaway is that the compliance relief and enforcement discretion for companies that show a “good faith effort” in year 1, which many expected companies to rely on, wasn’t actually used. The biggest surprise here is the level of ambition. Peers chose to go beyond the minimum without anyone forcing them. Companies that report once the rule goes live will be measured against that bar, not against what CARB technically requires.

The other signal is integration. SB 261 covers climate-related financial risk disclosure, while SB 253 – with an active deadline of August 10, 2026 – requires annual GHG emissions reporting under the GHG Protocol, starting with Scope 1 and 2 this year and Scope 3 beginning in 2027. The 25% of voluntary reporters who included emissions data alongside their climate risk disclosure weren’t required to do so, but they were doing the work that will be mandatory within months if they meet the $1 billion revenue threshold under SB 253.

If you haven’t started, don’t treat the court pause as a reprieve. The bar has been set by peers who didn’t wait for one.

What Do These Reports Signal for the Market?

The voluntary disclosures submitted to California’s public docket should not be viewed as a new reporting standard. Rather, they provide an early snapshot of how a subset of companies chose to approach climate risk reporting despite the regulatory uncertainty.

For organizations still preparing for potential future requirements, these reports offer a practical resource. They show the types of climate risks being discussed, the frameworks being used, and the level of detail companies are currently providing. As California’s legal process continues, these disclosures may help companies better understand what climate risk reporting could look like in practice.

What we see working with companies through this process is that the groundwork for SB 261 and SB 253 is more connected than most assume. The data you need for emissions reporting informs your climate risk disclosure, and vice versa. Companies that approach them together are in a meaningfully better position than those treating them as separate projects.

There is no timeline for when a verdict will be made on the rule’s legal challenges. But the direction is already visible. Companies that have used the legal pause as breathing room may find themselves benchmarking against peers who didn’t wait.