California Air Resources Board Is Still Wrestling With Draft Regulations

In an article published in Pratt's Energy Law Report, Sidley lawyers Caleb J. Bowers, Maureen F. Gorsen and Michael J. Martinez examine recent guidance from the California Air Resources Board (CARB) as it develops regulations to implement California's climate disclosure laws, Senate Bill (SB) 253 and SB 261. The article reviews key developments from CARB's March 2026 public workshop, including proposed approaches to greenhouse gas (GHG) emissions reporting, organizational boundaries, Scope 3 accounting methodologies, phased implementation and assurance requirements, while highlighting practical compliance considerations and regulatory issues businesses should monitor as the rulemaking process continues.