SB 261 Voluntary Filers & Transition Plan Gaps

At a glance

SB 261 vs SB 253

Key findings

1. 188 companies have a voluntary SB 261 climate-related financial risk report on the California Air Resources Board's public docket (re-pulled Oct 11, 2026). Enforcement of SB 261 is paused by a Ninth Circuit injunction, so every one of these filings is voluntary. We reviewed 187 of the 188 reports; the one we could not review is Premier Packaging, whose current report we could not find online.
2. 87 of 187 reviewed reports (47%) describe a climate transition plan, 18 of them borderline. The other 100 do not (16 borderline), and 90 of 187 reviewed reports set no emissions reduction target at all.
3. Only 34 of 187 reviewed reports (18%) put a dollar figure on climate-related downside. 111 describe their risks in words or ratings only, and 41 say they assessed exposure or ran the numbers but publish no figure.
4. 12 of the 34 reviewed reports that quantify climate risk have no transition plan. Resonetics models a $23M decline in asset value and says it has not acted or set targets; Rady Children's Hospital puts flood and storm losses at $53M to $131M with no emissions targets; Halozyme Therapeutics charts a carbon cost of up to about $25M by 2050 with no reduction targets; Palomar Health prices utility outages at $0.5M to $1M a day.
5. Some of the biggest numbers sit in parent-company documents: AGC Inc. (for AGC America) puts carbon pricing at up to about $1.4bn a year under a net-zero scenario, Infosys Ltd puts heat and water stress at $31M to $35M a year, and Tate & Lyle PLC estimates $25M to $30M from water stress on corn sourcing. 33 of 187 reviewed reports rely on group-level documents.
6. Targets can also move the wrong way. MongoDB pushed its net-zero year from 2030 to 2050 as its reported emissions rose about 48%, and Frontier Group Holdings calls itself America's greenest airline by fuel efficiency but has no emissions reduction target in its 10-K.

The data

Methodology & sources

We pulled every released submission from the California Air Resources Board's public docket for Climate-Related Financial Risk Reports (SB 261), first on Sept 11, 2026 and again on Oct 11, 2026. The Oct 11 re-pull added 17 submissions, for 188 in total: one row per released submission, one company per row, sorted A to Z.

We read each company's filed report in full (the document on CARB or the report the filing links to) and recorded two calls, a qualifier for each, the gap types, page-referenced evidence and a short note on what the gap signals. As of Oct 11, 2026, 187 of 188 reports are reviewed. Premier Packaging is not: its filing points to a sustainability page that does not link to a current report.

On Oct 11, 2026 we applied the rubric below to every reviewed report, standardised the qualifier wording and re-graded six transition-plan calls that did not fit it.

Transition plan = Yes when the report sets targets with a size and a date plus named levers or a plan. Borderline = an intensity-only target, an undisclosed target size, an aspirational goal or an unpublished plan.

Quantified financial impact = Yes when the report gives a downside dollar figure, range or band, or a share of EBITDA or cash flow. Past-event losses count. Parent-company figures count, with a caveat. A figure that sits only in an external document counts only with a qualifier. Upside-only dollar figures, a carbon price used only as an input, exposure without dollars, and analysis that is not disclosed are No.

The docket opened Dec 1, 2025 and the submittal window runs to Dec 31, 2026. CARB reviews submissions for 3 to 4 weeks before releasing them, so the docket lags actual filings.

A Ceres / G&A Institute analysis (Sept 1, 2026) covered 154 filers as of early May 2026; the docket has grown to 188 since. Ceres / G&A Institute report.

Definitions

Voluntary filer

A company whose SB 261 climate-related financial risk report CARB has released on its public docket. Enforcement of SB 261 is paused by a Ninth Circuit injunction (Chamber of Commerce v. Sanchez), so every filing is voluntary.

Transition plan: Yes / Yes (borderline) / No (borderline) / No

Yes means the report sets emissions reduction targets with a size and a date, and names the levers or plan to reach them. Borderline means a close call: an intensity-only target, an undisclosed target size, an aspirational goal, or a plan that is referenced but not published. No means no targets, or targets without a plan.

Quantified financial impact: Yes / No

Yes means the report puts a dollar figure, range or band, or a share of EBITDA or cash flow, on climate-related downside. Losses from past events count. A parent company's figures count, with a caveat. Figures that sit only in an external document (such as a CDP response) count only when the report points to them, and the qualifier says so. Upside-only dollar figures, a carbon price used only as a model input, exposure without dollars, and analysis that is not disclosed all count as No.

Not yet reviewed

The report has not been read yet (1 row: Premier Packaging, whose current report we could not find). It is never counted as No.

Gap types

No targets

No emissions reduction target with a size and a date yet (includes targets still being evaluated or only aspirational).

Targets but no plan

Targets are set, but the report names no levers or plan to reach them.

Borderline

At least one of the two calls (transition plan, quantified impact) is a close call; the qualifier in the download says why.

Qualitative only

Risks are described in words or High / Medium / Low ratings, with no dollar figures.

Exposure, no $

Exposure was assessed (hazard maps, scores, scenarios) but no dollar figure is given.

Analysis done, not disclosed

The report says financial impacts were modelled or quantified, but publishes no figure.

Upside $ only

Dollar figures are given only for opportunities (for example green revenue), not for downside.

Carbon price as input only

A carbon price is used in planning or investment decisions, but no resulting impact figure is disclosed.

Group-level only

The report is the parent or group's document; the filing entity is not broken out.

Quantified downside disclosed

A strength, not a gap: the report puts a dollar figure, range, band or % of EBITDA or cash flow on climate-related downside.

Sources

• California Air Resources Board, Climate-Related Financial Risk Reports (SB 261) public docket · Pulled Sept 11, 2026; re-pulled Oct 11, 2026
• Each company's filed report (on CARB, or on the company's own site for link-only filings) · Linked per row where the company hosts it; CARB-hosted files are not linked
• Ceres and G&A Institute, Trends in Climate Risk Reporting: Lessons from Initial Voluntary Corporate Reports under California's SB 261 · Context only (Sept 1, 2026; covered 154 filers as of early May 2026).

Caveats

• Calls are about the filed report only, not a company's whole climate program. Borderline calls are marked, and the qualifier in the download says why.
• Resubmission rows are later filings by the same company; the list is otherwise as released by CARB, one row per released submission.
• 33 of 187 reviewed reports rely on a parent or group document (e.g. Matheson Tri-Gas uses parent Nippon Sanso's TCFD disclosure, AGC America uses AGC Inc.'s). Their calls reflect the group document and are flagged 'parent-company level' in the qualifiers. Baker Tilly filed jointly with Moss Adams.
• The Estée Lauder Companies is rated quantified only via the CDP response its report's TCFD index cites; scoped strictly to its own report it would be No.
• Schneider Electric's report URL in its CARB filing is dead (404); a working URL is used.
• 25 reports live only on CARB and are not linked here; open CARB's public docket to find them.
• Legal status (the Ninth Circuit injunction pausing enforcement) is as of Oct 11, 2026.

Related reading

• BlogDecoding ESG Signals: When Does a Commitment Become a Budget?
• BlogWhat We Look For Before a Company Gets Added to a Client's Pipeline

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