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Setting the Floor: New FAR Rule Defines Minimum Contractor Information System Safeguarding

Client Alert | 1 min read | 05.17.16

Shifting approaches, on May 16, 2016, the FAR Council concluded a long-running rulemaking with a final rule and a new clause, FAR 52.204-21, that will establish minimum security controls pulled from NIST Special Publication 800-171 over contractor information systems that may process, store, or transmit “Federal contract information,” defined as information provided to or generated under any government contract (except for COTS) that is not intended for public release. Future rules will address more specific controls applicable to more sensitive information such as Controlled Unclassified Information (CUI), but this rule focuses instead on establishing those baseline controls the FAR Council believes any prudent business would implement in relation to its information systems and does not replace more stringent security requirements like those in the DFARS Safeguarding Rule.

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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....

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