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With the deadline to publish SB 261-compliant climate risk reports rapidly approaching (January 1, 2026), and with legal challenges slowly moving through the court system in the U.S. District Court for the Central District of California and the Ninth Circuit, it perhaps comes as little surprise that industry groups have now sought the emergency involvement of the Supreme Court of the United States (“SCOTUS”).

On November 7, 2025, U.S. Environmental Protection Agency (“EPA”) Administrator Lee Zeldin signed a final rule granting Texas primary permitting authority over Class VI Underground Injection Control (“UIC”) permits within the state.

Across sectors and jurisdictions, the data point to a world facing more frequent and intense physical disruptions. Extreme heat, heavy rainfall, rising sea levels, and prolonged droughts are no longer regional anomalies; they are macroeconomic factors shaping markets, policy, and investment strategy. The economic toll is mounting: physical damage from extreme weather cost the global economy at least $1.4 trillion last year, according to data compiled by Bloomberg Intelligence.

A federal district court in Louisiana has rejected as unlawful President Joe Biden’s withdrawal in early January 2025 of historically large portions of the Outer Continental Shelf (“OCS”) from eligibility for leasing of oil and natural gas.

An oil major (“the Company”) filed suit in federal court on October 24, 2025, challenging California’s Climate Laws — the Climate Corporate Data Accountability Act (“SB 253”) and the Climate-Related Financial Risk Act (“SB 261”) — on the basis that the laws violate the Company’s First Amendment rights.

From October 14–17, 2025, the Marine Environment Protection Committee (“MEPC”) of the International Maritime Organization (“IMO”) convened an extraordinary session in London to consider formal adoption of draft amendments to Annex VI of the International Convention for the Prevention of Pollution from Ships, including the IMO Net-Zero Framework.

On October 15, 2025, Louisiana Governor Jeff Landry issued an Executive Order (“Order”) halting the review of all new Class VI Underground Injection Control (“UIC”) well permits in the state and directed the state’s regulator, the Louisiana Department of Conservation and Energy (“LDCE”) to undertake a more careful review of pending Class VI permit applications.

On September 18, 2025, the United States Environmental Protection Agency (“EPA”) published its latest proposed policy in an active year for the Clean Air Act (“CAA”) Renewable Fuel Standard (“RFS”) program.

What can project developers actually build before securing an air permit?

On August 18, 2025, a divided panel of the U.S. Court of Appeals for the Fourth Circuit reversed a district court order dismissing an ethylene oxide (“EtO”) exposure case for lack of Article III standing.

On August 22, 2025, the Environmental Protection Agency (“EPA”) announced decisions on 175 small refinery exemption (“SRE”) petitions stretching back over the last four years.

On August 13, 2025, the U.S. District Court for the Central District of California denied a motion for preliminary injunction to enjoin California Senate Bills 253 and 261.