If your business falls under California’s SB 261, you’ll know the first statutory deadline was set for January 1, 2026, for publishing your Climate-Related Financial Risk Report. While enforcement has been temporarily paused pending appeal, the California Air Resources Board (CARB) has opened its public docket, and compliance will likely resume later in 2026. 

 

So, how’s your process going? How confident are you in your first draft? 

Chances are, there are gaps and areas for improvement – and that’s okay. Disclosures can only reflect what’s actually in place and that’s where Morelli Consulting comes in. We work with you to identify opportunities to strengthen both your performance and disclosure. 

 

Morelli’s climate services team can help:

✅ Build your understanding of climate-related risks, impacts and dependencies 

✅ Build and evolve your climate strategy and transition pathway

✅ Refine your target setting, data governance and management

✅ Improve disclosure quality and transparency.

 

In preparation for SB253, which follows hot on the heels of SB261, we can also help you: 

✅ Produce GHG Protocol aligned carbon emissions inventories for all emission scopes. 

✅ Validate your data and controls preparing you for assurance, including managing the process with your assurance partner. 

 

The CARB reporting deadline is 10 August 2026 for Scope 1 and 2 data for fiscal 2025, pushed back from 30 June 2026. Independent third-party assurance is formally required for Scope 1 and 2 emissions. Initially this will require limited assurance, moving to reasonable assurance over time. However, CARB have indicated they will be exercising a degree of enforcement discretion and flexibility if there is no assurance. 

Scope 3 emissions disclosure begins in 2027 with assurance following in later phases. CARB will set provider qualifications and standards to ensure consistency and integrity, aligning with global frameworks like the GHG protocol. 

 

Global mandatory climate disclosure isn’t just coming, it’s here. The question is: will your reporting simply tick the compliance box, or will it become a strategic advantage? 

At Morelli, we go beyond compliance. We’ll help you meet regulatory requirements, align functions and manage reputational risk, while building robust internal processes and controls. But we won’t stop there – we’ll also challenge you to braver and bolder, so you can lead with impact, work smarter and be resilient. 

Forward-thinking businesses are using climate strategies to drive innovation, strengthen investor confidence, and unlock new opportunities. Don’t wait for regulation to force your hand, get in touch with Morelli today and let us help you lead the way in building a resilient, future-ready business.