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London Reporting Academy California SB 261 · Climate-Related Financial Risk Act · Disclosure SB261-REPORTING-TIMELINE

Biennial reporting timeline and enforcement status

SB261-REPORTING-TIMELINE · mandatory · narrative disclosure

SB 261 enforcement is paused pending appeal. The law has not been cancelled. Record the current court and CARB position separately from the statutory biennial reporting cycle. Early publication alone does not make reporting voluntary.

Disclosure focus

The practical question is how broadly the reporting approach is applied across the business. Organisations should think about whether the information covers the parts of the group or operations that are relevant to the disclosure, not just a single flagship site or a narrow pilot area. The aim is to show a consistent, organisation-wide reporting rhythm that can be maintained over time.

This LRA educational guidance supports disclosure preparation. For the exact requirements, always refer to the official CARB source.

Prepare

What to collect before drafting

Tick each field as the evidence lands. Owners are the teams that usually hold the source files.

  • Reporting frequency

    Legal / Sustainability reporting

    Whether this filing is due every two years or not, based on the organisation’s current reporting obligation.

    Evidence Legal/compliance tracker, reporting calendar, or statutory assessment note showing the current filing cadence.

    Watch for Frequency set against the wrong statutory basis, so an annual cycle is treated as biennial or vice versa.

  • Enforcement position

    Legal / Compliance

    The present status of how the requirement is being enforced, using the latest official position the organisation is relying on.

    Evidence Regulatory update log, legal memo, or counsel note recording the current enforcement view and date checked.

    Watch for Current enforcement position not refreshed, so the team relies on an outdated status after the regulator’s position has changed.

  • Covered reporting period

    Sustainability reporting / Finance

    The time span the report is meant to cover, with clear start and end dates for the cycle being reported.

    Evidence Reporting calendar, policy note, or board paper stating the period covered for this filing.

    Watch for Reporting window mis-set, so the filing covers the wrong period or mixes a full cycle with a partial one.

  • First filing deadline

    Legal / Compliance

    The date by which the first report must be filed under the statute, as currently interpreted for the organisation.

    Evidence Statutory tracker, legal advice, or compliance calendar showing the first due date and basis for it.

    Watch for First deadline calculated from the wrong trigger date, so the filing date slips against the statutory timetable.

  • Filed on date

    Sustainability reporting / Legal

    The actual date the report was submitted, as recorded by the filing process or portal confirmation.

    Evidence Submission receipt, portal confirmation, or email acknowledgement showing the date and time sent.

    Watch for Submission date taken from draft approval or internal sign-off instead of the portal receipt, so the recorded date is wrong.

  • Voluntary filing flag

    Legal / Sustainability reporting

    Whether the report was submitted voluntarily rather than because it was due under the current obligation.

    Evidence Filing decision note, legal assessment, or submission record showing the voluntary status at the time of filing.

    Watch for Voluntary status not aligned to the filing decision, so an optional submission is recorded as mandatory or the other way round.

Before you start

  • Have you confirmed whether this sits on a two-year reporting rhythm for your organisation, or not?
  • Which reporting period are you using for this entry, and does it match the cycle you are covering?
  • Can you point to a source for the first due date and the date you actually submitted?
  • Is the current position one of active enforcement, paused enforcement, or another status you can evidence?
  • If the filing was made without a legal obligation, have you clearly marked it as voluntary?
+ Show SB261-REPORTING-TIMELINE sub-elements (LRA working checklist)

How to prepare it

Confirm whether this filing is on the two-year reporting rhythm and note the organisation’s current position on enforcement, so the timeline basis is clear before you start drafting.
Set the reporting period you are covering and identify the first date the law expects for this report, using the same period consistently across the pack.
Gather the source records that support the timeline entries, including internal approvals, filing logs, and any dated evidence that shows when the report was prepared and sent.
Prepare the final timeline details in plain language: the period covered, the first statutory due date, the actual submission date, and whether the filing was made as a voluntary action.
Record any exclusions, assumptions, or changes in status that affect the timeline, and explain why they were applied so the evidence trail is easy to follow.
Check the completed disclosure against the official source before release, making sure the dates, status statements, and reporting-cycle description still match the latest authoritative guidance.

Request the data

Request the reporting timeline and filing status details

Translate the disclosure into an internal business question — then adapt it to your organisation's own language.

Are we on a biennial filing track for this reporting cycle, and what is the current status of the filing, deadline, and any voluntary submission record?

Use your organisation’s own labels first, then map them to the reporting timeline fields. For example, if your team talks about filing windows, submission tracking, or regulatory notices, use those terms in the request and only translate them into the disclosure fields when you compile the evidence. This is a possible LRA training template; adapt it to your organisation and check the source material before sign-off.

Weak request

Please provide the SB 261 reporting timeline evidence and enforcement status for the disclosure.

Why it fails: It uses framework language that may not match how the business tracks filings, and it does not tell the owner which internal record to pull, which dates matter, or how to distinguish a planned filing from a voluntary submission. That makes it harder to answer quickly and consistently.

Better request

Please send the filing calendar entry, legal tracker extract, or board-approved note for [reporting cycle] covering [entity/group], showing whether this cycle is on a biennial filing track, the current filing status, the first-filing deadline used, the submission date, and whether any filing was made voluntarily. Include the source, last-updated date, and any short status note.

Formal email template
Subject: Request for filing timeline and status evidence for [reporting cycle]\n\nDear [name/team],\n\nPlease could you share the evidence we need for the [reporting cycle] filing timeline and status check for [entity/group]? We are looking for the internal record that shows:\n- whether this reporting cycle is on a biennial track\n- the current filing status\n- the deadline used for the first filing in scope\n- the submission date, if already sent\n- whether any submission was made on a voluntary basis\n\nPlease include the source record, the date it was last updated, and any note that explains the status. If the information sits in a tracker, board paper, legal memo, or filing calendar, a copy or extract is fine.\n\nThis is a possible LRA training template; please adapt it to your organisation’s own terms and check the source material before sign-off.\n\nMany thanks,\n[preparer name]
Short Teams / Slack version
Hi [name/team] — could you send over the filing tracker / legal note / calendar entry for [reporting cycle] covering [entity/group]? We need the record showing whether this is on a biennial track, the current filing status, the first-filing deadline used, the submission date, and whether anything was filed voluntarily. Please add the source and last-updated date. Thanks.

Industry examples

Financial services

Context. A regulated group tracks climate-related filings through Legal and Company Secretariat, with deadlines logged in a compliance calendar.

Adapted request. Please share the compliance calendar entry and any supporting note for [reporting cycle] covering [entity/group], showing whether this filing cycle is on a biennial track, the current filing status, the first-filing deadline used, the submission date, and whether any filing was made voluntarily.

Example response. Illustrative planning record: reporting period, statutory timing, current enforcement position, publication date and legal basis for treating publication as voluntary. Publish after the stated reporting period ends. Early publication alone does not establish voluntary status.

Manufacturing

Context. A group with multiple subsidiaries keeps filing status in a central legal register managed by Company Secretariat.

Adapted request. Please provide the legal register entry for [reporting cycle] covering [entity/group], including the filing track, current status, first deadline, submission date, and any voluntary submission note. If the register uses different labels, keep those labels and add a short mapping note.

Example response. Illustrative planning record: reporting period, statutory timing, current enforcement position, publication date and legal basis for treating publication as voluntary. Publish after the stated reporting period ends. Early publication alone does not establish voluntary status.

Draft your disclosure

Notes that turn data into a disclosure

LRA training templates — adapt them to your organisation, and check the official source before sign-off.

Method note

State how you defined each field, including whether the filing was treated as required or voluntary, which reporting period was used, and how the deadline and submission date were captured from the source records.

Context note

Explain that these figures describe the filing position for the period in question, showing both the legal timing expectation and the organisation’s actual submission outcome.

Fluctuation statement

If the filing date moved relative to the deadline or the reporting period changed, note the operational or timing reasons behind that shift and whether the submission remained required or was made voluntarily.

Content index entry

SB261-REPORTING-TIMELINE Biennial reporting timeline and enforcement status — [location / page] / [notes]

Download Centre

Preparation tools & forms

Download preparation tools for SB261-REPORTING-TIMELINE with free verified email access for 24 hours. Source-report links remain public.

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Check

For each claim, check the evidence

  • I have checked whether this entity is in scope for the California climate-risk filing and whether the reporting obligation applies to it.

    Risk Assurance will test whether the in-scope assessment is correct and supported by the legal-entity analysis, because an incorrect yes/no conclusion would make the whole disclosure misleading.

    Evidence to check Entity scoping memo; legal-entity register; applicability assessment against the cited California provisions; internal sign-off showing why the entity is or is not covered.

  • I have used the current enforcement position to describe the regulatory consequence of not publishing, or of publishing something that is not adequate.

    Risk The assurer may probe whether the statement overstates, understates, or misstates the regulator’s present powers, or whether it is based on outdated legal review.

    Evidence to check Latest legal review or counsel note; source materials on the regulator’s current penalty powers; version control showing the date the enforcement position was last checked; approval record for the wording used.

  • I have identified the reporting period that the disclosed timetable relates to and matched it to the correct cycle.

    Risk The main risk is that the period described is the wrong one, overlaps the wrong year, or is inconsistent with the entity’s reporting calendar.

    Evidence to check Reporting calendar; board or management paper confirming the period selected; cross-reference to the period used in the disclosure pack; evidence that the same cycle is used consistently across the report.

  • I have stated the first required date and the repeating pattern in a way that matches the statute and our internal timetable.

    Risk The assurer will check whether the date and cadence are accurate and whether the disclosure has accidentally shifted the timing or implied a different sequence.

    Evidence to check Statutory interpretation note; compliance calendar; draft-to-final change log; sign-off from legal, compliance, or reporting owners confirming the timing statement.

  • I have recorded the date the report was made public or filed, and that date is supported by the publication trail.

    Risk Assurance will test whether the date is real, complete, and aligned with the actual release or filing event, rather than a planned or draft date.

    Evidence to check Website publication record; filing receipt or submission confirmation; timestamped email or portal evidence; archive copy of the final version with the same date.

  • I have explained the route we used to meet the requirement where we did not use a direct statutory filing route, and the method is consistent with the chosen compliance approach.

    Risk The assurer may ask whether the method described truly satisfies the obligation, whether it was approved in advance, and whether the disclosure is describing the same route that was actually used.

    Evidence to check Compliance strategy paper; legal advice on the chosen route; records of any voluntary or equivalent submission; evidence that the method used matches the one described in the disclosure.

Evidence pack to prepare

Common reporting gaps

  • The information is presented without a date or as-at point.
  • The scope or boundary of the statement is left undefined.
  • Key terms are used inconsistently across the report.
  • Material changes since the previous period are not disclosed.
  • Assertions are made without supporting detail or a source record.
  • Boilerplate is used that does not actually answer what is asked.

Where drafts go wrong

Mistakes to avoid and where judgement is needed

The left column is what preparers get wrong while collecting; the right column is where you will have to make and explain a judgement.

Mistakes to avoid

  • Ask the right ownerThe request goes to a policy lead or legal contact instead of the team that actually tracks filing dates, so the answer comes back in framework language rather than the organisation’s own terms.
  • Set the boundary firstPeople start collecting dates and status without agreeing which entity, business unit, or filing population is in scope, so later evidence cannot be tied back to one clear boundary.
  • Use one time basisOne team uses the calendar year, another uses the reporting cycle, and the resulting dates cannot be compared because they were not gathered on the same basis.
  • Keep the original labelsSource files are copied into a summary sheet and the original field names, notes, and file titles are lost, making it hard to trace where each date or status came from.
+ Show 5 more

Judgement needed

  • Choosing the reporting cycle after a group changeIf acquisitions, disposals or restructurings change the business perimeter, fix one cut-off basis for the cycle covered, explain which entities were included or left out, and keep the same basis for the dates you report.
  • Handling different country calendars and filing clocksWhere local reporting calendars differ, use one organisation-wide date basis for the cycle and submission date, then note any country-level timing differences that affected the filing plan.
  • Deciding whether a borderline entity is in scopeFor entities near the edge of coverage, apply the same internal test consistently, state the judgement used, and disclose any exclusions or inclusions that were not obvious.
  • Setting the first deadline when the law changes mid-cycleIf the first filing date is affected by a change in status or an update to the legal position, document the date you used, why it was chosen, and whether the filing was made on a voluntary basis.
+ Show 4 more

Examples

How it reads on the page

Synthetic, written by LRA — not from a company report, not text from any standard.

Illustrative (synthetic) example — Utilities

Illustrative planning record: reporting period, statutory timing, current enforcement position, publication date and legal basis for treating publication as voluntary. Publish after the stated reporting period ends. Early publication alone does not establish voluntary status.

SB 261 enforcement is paused pending appeal. The law has not been cancelled. Record the current court and CARB position separately from the statutory biennial reporting cycle. Early publication alone does not make reporting voluntary.

Illustrative (synthetic) example — Consumer goods

Illustrative planning record: reporting period, statutory timing, current enforcement position, publication date and legal basis for treating publication as voluntary. Publish after the stated reporting period ends. Early publication alone does not establish voluntary status.

SB 261 enforcement is paused pending appeal. The law has not been cancelled. Record the current court and CARB position separately from the statutory biennial reporting cycle. Early publication alone does not make reporting voluntary.

Quality ladder

  • Basic

    I filed on 2025-06-30.

  • Better

    Illustrative planning record: reporting period, statutory timing, current enforcement position, publication date and legal basis for treating publication as voluntary. Publish after the stated reporting period ends. Early publication alone does not establish voluntary status.

  • Best

    Illustrative planning record: reporting period, statutory timing, current enforcement position, publication date and legal basis for treating publication as voluntary. Publish after the stated reporting period ends. Early publication alone does not establish voluntary status.

Check your understanding

Scenarios to work through

A preparer is updating the filing tracker for a company that has already sent one climate report and is now planning the next one. The team is unsure whether to treat the filing as part of a repeating two-year cycle or as a one-off update.

QShould the tracker show that this disclosure follows a repeating two-year reporting pattern, and what cycle should be recorded?
Reveal model answer →

A draft pack shows a submission date, but the legal team has not yet confirmed whether the law is currently being enforced for this company’s filing route. The preparer is about to finalise the disclosure anyway.

QCan the disclosure be signed off without a current enforcement status, or does that status need to be captured first?
Reveal model answer →

A company missed its expected first filing date in the prior year and is now preparing a late submission. The preparer has the actual send date, but the draft does not yet show the statutory first deadline that the team was working to.

QShould the disclosure include both the deadline that applied and the date the report was actually sent?
Reveal model answer →

A sustainability manager wants to describe the filing as voluntary because the company chose to publish early, even though the team is also tracking the legal timetable and enforcement position. The draft currently mixes those ideas into one sentence.

QHow should the preparer separate the voluntary aspect from the legal timeline so the disclosure stays clear?
Reveal model answer →

Real reports

How 3 companies report it

Examples of full and partial reporting practice. These are evidence-led reviews, not exact disclosure templates to copy.

Real published reports

Owens Corning

Related

Building Products · United States · 2024 · p.100 ↗

Owens Corning’s 2024 Sustainability Report specifies the reporting cycle as January 1, 2024 to December 31, 2024, indicating the timeframe covered by the assessment (p.383). The report includes an assurance statement confirming management’s responsibility for the report’s preparation and content (p.381). However, there is no evidence found regarding the statutory first deadline, submission date, voluntary submission status, or biennial reporting requirements under SB261.

Host Hotels & Resorts, Inc.

Related

Real Estate · United States · 2025 · p.27 ↗

Host Hotels & Resorts, Inc.'s 2025 Corporate Responsibility Report includes a GRI content index covering the period from January 1, 2024, to December 31, 2024, indicating a defined reporting cycle (p.62). The report references various ESG-related appendices and disclosures, such as TCFD references (p.57) and performance tables (p.53), but does not provide specific information on the SB261 reporting timeline requirements like biennial reporting, statutory deadlines, or submission dates. Notably, there is no evidence in the report regarding the current enforcement status or voluntary submission status for SB261 disclosures.

Republic Services

Related

Solid Waste Management Utilities · United States · 2024 · p.8 ↗

Republic Services’ 2024 Sustainability Report includes information on its environmental health and safety (EHS) program, which covers environmental compliance and employee health and safety goals such as incident reduction and safety amplification (p.6). The report also highlights efforts to improve worker safety through equipment upgrades, like the transition to automated side-load trucks and new recycling carts, reducing manual waste handling (p.10). However, there is no evidence in the report regarding the SB261 reporting timeline, enforcement status, submission dates, or voluntary submission status.
FieldOwens CorningHost Hotels & Resorts, Inc.Republic Services
Reporting frequencyNot foundNot foundNot found
Enforcement positionNot foundNot foundNot found
Covered reporting periodNot foundNot foundNot found
First filing deadlineNot foundNot foundNot found
Filed on dateNot foundNot foundNot found
Voluntary filing flagNot foundNot foundNot found

Full evidence map with quotes and page numbers →

✓ Knowledge Hub AI Assistant · Human-in-the-loop
Dr Ross Kurinko

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Framework references

Relevant California requirements and related disclosures

California

SB261-REPORTING-TIMELINE

within California SB 261: Climate-Related Financial Risk Act

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FAQ

Questions this page answers

SB261-REPORTING-TIMELINE: what data do I need to gather before I start the disclosure draft?+
How do I use the SB261-REPORTING-TIMELINE page to set the reporting period and filing date correctly?+
What should I include in the evidence pack for SB261-REPORTING-TIMELINE assurance readiness?+
How do I use the six assurance claims on the SB261-REPORTING-TIMELINE page in practice?+
What are the common mistakes on the SB261-REPORTING-TIMELINE page that I should avoid?+
How do I use the SB261-REPORTING-TIMELINE workbook download to prepare the disclosure?+
What is the printable Library Card PDF for SB261-REPORTING-TIMELINE used for?+
Can I use the synthetic example disclosure on SB261-REPORTING-TIMELINE as a template for my own draft?+
How do I turn the SB261-REPORTING-TIMELINE page into a first draft disclosure?+
Is the data I collect for SB261-REPORTING-TIMELINE reusable for ESRS E1 climate reporting?+
Who should own the SB261-REPORTING-TIMELINE disclosure process in my organisation?+

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