Explore the Reporting Edition

Preparing for California SB 261: a guide for decision makers
Metal span bridge in and industrial section of Long Beach California.
© iStock / Getty Images
DISCLAIMER: This article does not endorse SB 261 or provide legal advice. It is intended purely as an informational resource to help readers understand the current state of developments and what is publicly known about the timeline and requirements.  

Busy day? Here’s the summary

California SB 261 is a state law that, once implemented, will require companies with annual revenue above $500 million and doing business in California to publish a climate-related financial risk report. The first reports are scheduled for January 1, 2026, covering the most recent financial year (typically 2025). However, key definitions such as what constitutes “doing business” and how the $500M threshold is calculated remain subject to clarification by the California Air Resources Board (CARB).

SB 261 update

As of October 2025, CARB has announced that final rulemaking will not be completed until Q1 2026, even though the statutory reporting deadline remains unchanged. This creates a situation where companies may need to prepare under regulatory uncertainty and demonstrate good-faith efforts to comply. Companies should monitor CARB updates and FAQs closely.

Who is in scope and what to disclose

Here’s what we know so far: SB 261 applies to large private and public companies that meet the revenue threshold and are doing business in California, including organizations headquartered elsewhere with a California footprint. Reports have to be hosted on the company website and lodged with CARB. Disclosures could follow a recognized framework such as TCFD or IFRS S2 and clearly set out governance, strategy, risk management, and metrics.

Key definitions, such as what counts as “doing business” and how $500M revenue is calculated, are still pending CARB clarification (as of October 20, 2025).

Key terms

  • SB 261
    California Climate-Related Financial Risk Act requiring biennial public reports
  • CARB (California Air Resources Board)
    The state agency responsible for implementing SB 261, issuing guidance and checklists, and enforcing compliance (including penalties for non-compliance).
  • TCFD / IFRS S2
    Widely used disclosure structures that organise climate reporting around governance, strategy, risk management, metrics and targets

How to get started on reporting

Here are six actionable steps to help you prepare for SB 261 compliance:

  • Define governance: Assign accountable executives and set board review frequency.
  • Map your footprint: Compile a complete list of sites, operations, and key suppliers.
  • Assess hazards: Evaluate exposure to wildfire, flood, heat stress, and coastal risk, and link findings to financial planning horizons.
  • Test resilience: Add a brief scenario analysis (qualitative is encouraged; quantitative is not mandatory per CARB draft guidance as of October 2025).
  • Strengthen data: Close gaps, standardize hazard layers, and document methods for audit readiness.
  • Evaluate financial impact: Translate climate risk findings into potential financial implications for assets, operations, and long-term planning.

Disclosure as operating advantage

Location Risk Intelligence’s Reporting Edition supports CSRD and EU Taxonomy requirements and aligns with ISSB (IFRS S2), the TCFD successor, using IPCC‑based scenarios and standard projection years (2030, 2050, 2100). It also enables financial impact assessments, helping organizations link physical risk exposure to potential economic consequences – an increasingly important expectation in climate-related disclosures.

No matter if single site or entire portfolios: Reporting Edition turns assessments into standardized five‑band risk scores with ready‑to‑use PDF/CSV/Excel reports and a REST API for seamless integration into ESG workflows and internal systems. Outputs mirror ISSB/TCFD pillars so you can assemble a public, decision‑useful SB 261 report without reinventing your method every time.

As of October 2025, the Reporting Edition covers all 28 hazards referenced in EU Taxonomy/CSRD physical‑risk disclosure. This could be useful when U.S. teams face SB 261, but global stakeholders expect EU‑style completeness.

Case Study: Prologis

A global logistics leader adopted Location Risk Intelligence after evaluating multiple tools. The change was not only a stronger report. Portfolio management improved through peril-specific scores at asset level, integration into internal mapping, and investment decisions with 20- to 30-year horizons informed by consistent evidence. That is the type of discipline stakeholders expect under SB 261.

Get case study

With a global portfolio of our size, Prologis makes reliable measurement a priority to inform our data-driven decision-making process. Munich Re has been our trusted partner to measure the impact of climate change across our real estate portfolios.
Jeff Bray
Prologis
SVP & Head of Global Risk Management

How SB 261 could compare to TCFD and IFRS S2

Topic

SB 261 (California)

TCFD / IFRS S2

Who
Applies to public and private companies with annual revenue > $500M doing business in California.

TCFD: Voluntary, widely adopted globally.

IFRS S2: Mandatory in some jurisdictions (e.g., UK, Australia) since Jan 2024; built on TCFD principles.

Focus
Climate-related financial risk and measures to mitigate/adapt.
Governance, strategy, risk management, metrics & targets for physical and transition risks (and opportunities).
Frequency
Biennial reporting, posted publicly and linked to California Air Resources Board (CARB).
Annual reporting is best practice, often integrated into sustainability or financial reports.
Data emphasis
Possibly Narrative-driven, qualitative scenario analysis encouraged but not mandatory; no assurance required.
Principles-based, scenario analysis expected; IFRS S2 adds more prescriptive elements than TCFD.

Next steps you might want to take

If you want to act now, establish a clear pathway for SB 261 compliance and climate‑risk transparency over the next six months. Begin by confirming scope and accountability, then compile a reliable inventory of assets and activities covering California exposure and any material cross‑border dependencies.

You can run an initial risk scan with Location Risk Intelligence to identify hotspots such as wildfire, flood, heat stress, and coastal exposure. Use Reporting Edition to draft a structured disclosure aligned with TCFD or IFRS S2, incorporating a concise qualitative scenario view and a financial impact assessment to link physical risks to potential economic consequences.

Finally, document measures with assigned owners and timelines, prepare assurance‑ready workpapers, and position your organization to publish with confidence. Remember to steadily monitor CARB updates and litigation developments.

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