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Changes to Acquisition Thresholds On the Way

Client Alert | 1 min read | 07.29.15

On July 2, 2015, the FAR Council published a final rule, effective October 1, 2015, increasing the micro-purchase base threshold to $3,500 (from $3,000), that for use of simplified acquisition procedures for acquisition of commercial items to $7 million (from $6.5 million), the cost or pricing data threshold and the Cost Accounting Standard threshold to $750,000 (from $700,000), the prime contractor subcontracting plan floor to $700,000 (from $650,000), and the threshold for reporting first-tier subcontract information (including executive compensation) to $30,000 (from $25,000). The simplified acquisition threshold ($150,000) and the construction threshold ($1.5 million) will remain at current levels.


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Client Alert | 7 min read | 12.17.25

CARB Proposes Regulations Implementing California GHG Emissions and Climate-Related Financial Risk Reporting Laws

After hosting a series of workshops and issuing multiple rounds of materials, including enforcement notices, checklists, templates, and other guidance, the California Air Resources Board (CARB) has proposed regulations to implement the Climate Corporate Data Accountability Act (SB 253) and the Climate-Related Financial Risk Act (SB 261) (both as amended by SB 219), which require large U.S.-based businesses operating in California to disclose greenhouse gas (GHG) emissions and climate-related risks. CARB also published a Notice of Public Hearing and an Initial Statement of Reasons along with the proposed regulations. While CARB’s final rules were statutorily required to be promulgated by July 1, 2025, these are still just proposals. CARB’s proposed rules largely track earlier guidance regarding how CARB intends to define compliance obligations, exemptions, and key deadlines, and establish fee programs to fund regulatory operations....