Guide

CaliforniaSB261complianceguide2026:yourclimateriskreport

Learn who must comply with California SB 261, how to build a TCFD / IFRS S2 climate risk report across the four pillars, deadlines and the current legal status.

What's inside
  • Revenue threshold to fall in scope
  • Accepted reporting frameworks
  • Biennial climate risk report
  • Governance, strategy, risk, metrics
Dcycle Team ·
LegislationComplianceUSAClimate Risk

California’s Senate Bill 261, the Climate-Related Financial Risk Act, requires U.S. companies with more than $500 million in annual revenue that do business in California to publish a climate-related financial risk report every two years. Unlike SB 253, which is about emissions numbers, SB 261 is about the narrative: the climate risks your business faces and how you manage them. It is overseen by the California Air Resources Board (CARB), with penalties of up to $50,000 per reporting year.

What you’ll find in this guide

This guide helps you know exactly what SB 261 asks for and how to produce a report you can file with confidence:

  • What SB 261 is and who has to comply (the $500M threshold and the insurance exemption)
  • How to structure the report under the TCFD or IFRS S2 frameworks
  • The four pillars in practice: governance, strategy, risk management, and metrics & targets
  • The current legal status: the January 2026 deadline, the Ninth Circuit injunction and CARB’s enforcement stance
  • How SB 261 relates to SB 253 and why the same data serves both
  • Where to publish the report and how to submit it to CARB
  • A step-by-step path from cross-functional kickoff to a filing-ready report

Download the full guide

The hardest part of SB 261 is not the framework, it is turning cross-functional inputs from finance, risk, legal and sustainability into a credible narrative backed by real metrics. The companies that report well are the ones whose climate and emissions data is structured and traceable, so the metrics and targets pillar stands up to scrutiny. This guide shows you how to get there, and how to build it alongside your SB 253 disclosure from a single source of truth.

California SB 261 compliance guide 2026: your climate risk report

Download the full resource for free.

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Key highlights

$500M+ Revenue threshold to fall in scope
TCFD / IFRS S2 Accepted reporting frameworks
Every 2 years Biennial climate risk report
4 pillars Governance, strategy, risk, metrics

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