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Risk Of Accepting Out-Of-Scope Task/Delivery Orders Gets Greater

Client Alert | less than 1 min read | 10.07.04

Adding to the risk of accepting out-of-scope work that potentially could result in avoidance of the contract order, the GSA debarring official has recently put the burden on the contractor to police the situation: "We cannot have a situation where a contractor knows or should have known that something is wrong and does not at least raise the issue with the contracting officer, or, if appropriate, higher authority. On a case-by-case basis, if we determine that a contractor has not followed the rules, we may take appropriate action in the context of contractor responsibility."

Insights

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....