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On November 18, 2025, the U.S. Court of Appeals for the Ninth Circuit ordered a preliminary injunction on the enforcement of SB 261—the California law that requires large companies to publicly disclose their climate-related financial risks in biennial reports.

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.

In a potential watershed moment that could reverberate across companies that have set climate goals or made claims regarding climate ambitions (e.g., “net zero” or carbon neutrality), on October 23, 2025, a European oil major (the “Company”) was handed a potentially significant greenwashing ruling by the Paris Judicial Court (the “Court”), which found the Company’s claims about its role in the energy transition and its net zero ambitions were likely to mislead consumers.

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.

In the latest round of developments regarding California’s Climate Laws—SB 253 and SB 261—the California Air Resources Board (“CARB”) posted a Notice to its website on October 14, 2025, deferring its initial rulemaking on the laws until the first quarter of 2026 in response to the large volume of public comments it has received.

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?