Ninth Circuit Pauses Enforcement of California Climate Disclosure Acts
On Nov. 18, 2025 the Ninth Circuit halted enforcement of SB 261 and the Climate Corporate Data Accountability Act, creating uncertainty for companies reporting climate risks in California.
The Ninth Circuit’s decision to suspend enforcement of the California Climate‑Related Financial Risk Act (SB 261) and the Climate Corporate Data Accountability Act (SB ?) on November 18, 2025 follows a lawsuit challenging key provisions in both statutes. The pause means that, for the foreseeable future, firms will not face mandatory penalties for non‑compliance with required climate‑risk financial disclosures and corporate data accountability reports, but it also signals a broader regulatory uncertainty. For clients, the ruling underscores the need to review current ESG‑reporting frameworks, assess potential exposure to future enforcement, and prepare for possible reinstatement of compliance deadlines if the case is resolved in favor of the state. Law firms should advise clients to keep abreast of the litigation’s progress, engage with California regulators about interim guidance, and evaluate the impact on cross‑border reporting obligations that align with federal ESG reporting initiatives. The next watchpoint will be the appellate outcome, which could either restore enforcement timelines or refine the statutes’ scope.