Much of the focus around climate legislation coming out of the latest California legislative session has been on new, far-reaching requirements pertaining to disclosure of climate data and climate-related financial risk. However, California also adopted a third law related to climate change last year – AB 1305 – which has received somewhat less attention but may well have a wider and more immediate effect. Intended to address greenwashing claims, particularly related to voluntary carbon offsets (“VCO”), the Voluntary Carbon Market Disclosure Act mandates disclosure by entities that: (1) sell VCO credits in California; (2) buy or use VCO credits sold in California; and/or (3) make climate claims about corporate performance or products.