On November 18, 2025, the Ninth Circuit Court of Appeals (the Court) granted an injunction that stays enforcement of SB 261 while the Court reviews an appeal related to the ongoing litigation challenging SB 261 and SB 253 on First Amendment grounds. SB 261 requires public and private companies with greater than $500 million in total annual revenue that do business in California to prepare a climate-related financial risk report by January 1, 2026, and every two years thereafter, detailing their climate-related financial risks and efforts to reduce and adapt to such risks. Our recent Client Alert discusses this development and next steps for in-scope companies.