Implementation is well underway for California’s climate disclosure laws, SB 253 (Corporate GHG Reporting), SB 261 (Climate-Related Financial Risk Disclosure), and SB 219 amendments. Aimed at large companies formed in the U.S. and doing business in California, these require disclosure of climate-related financial risks by January 1, 2026, and corporate greenhouse gas (GHG) emissions by June 30, 2025. NOTE: SEE AMENDMENTS IN NOVEMBER 2025 FOR THE MOST UPDATED INFORMATION – LINK IS BELOW.
Two months remain in 2025 for companies to prepare a first climate risk assessment for reporting. Companies have 8 months to compile a verified Corporate Scope 1 and 2 reporting in mid-year, 2026.
Following the California Air Resources Board’s (CARB) workshop (8/21/25), CARB staff made several resources available and solicited stakeholder feedback. These resources include a
On October 14, 2025, instead of issuing draft regulations, as discussed at the August workshop, CARB proposed an updated timeline for bringing the initial rulemaking to the Board in Q1 2026. CARB continued to take feedback on the draft reporting template for Scope 1 and Scope 2 GHG emissions at CARB’s public docket through 10/27/25.
Click here for important SB 253 and 261 implementation resources and the notice.
2025 Timeline and Moving Forward
October 14 – Notice Delaying Regulations
October 10 – Corporate GHG Template and Memo for SB 253 published
September 2 – Climate-Related Financial Risk Disclosures Draft Checklist
Information from CARB’s August Public Workshop for 2026
Definition of Covered Companies – the “Who”
Due Dates
SB 261 Disclosure/Reporting Content
Preliminary Estimate of Covered Companies and Estimated Annual Fees (subject to change)
Assurance by 3rd parties
Next Steps:
Additional SB 253, SB 261 Resources:
California Air Resources Board Signals Intentions for Climate Regulations
At their August 21st public workshop, California’s Air Resources Board (CARB) significantly advanced implementation of the state’s climate disclosure laws. We are in the countdown!
These are SB 253 (Corporate GHG Reporting), SB 261 (Climate-Related Financial Risk Disclosure), and SB 219 amendments. Aimed at large companies formed in the U.S. and doing business in California, these require disclosure of greenhouse gas (GHG) emissions and climate-related financial risks starting in 2026.
Four months remain in 2025 for companies to prepare a first climate risk assessment for reporting. Companies have 10 months to compile Corporate Scope 1 and 2 reporting in mid-June, 2026.
NEW: CARB’s Current Regulatory Direction
For public comment, CARB provided their current thinking on draft rule language identifying a wide range of key details for implementation of the ‘200s’, as they referred to the 3 laws.
Definition of covered companies – the “Who”
Due Dates
Disclosure/Reporting Content
Preliminary Estimate of Covered Companies and Estimated Annual Fees
Assurance by 3rd parties
Next Steps
Resources:
Navigating U.S. Climate Emissions And Risk Disclosure Requirements: California Leads The Way
Join the Air and Waste Management Association (A&WMA) on March 19th for a 90-minute discussion of the sweeping new climate-related disclosure requirements covering climate risk and greenhouse gas emissions (GHG) finalized by the U.S. Securities and Exchange Commission (“SEC”) and the state of California in 2024. Both are subject to court challenges, with the implementation of the SEC rules now paused.
California’s laws have not been paused.
This presentation presents who is affected, the need-to-know elements of these new state and federal disclosure requirements, and what to do to prepare. Bonus material will be provided for climate and carbon requirements in the EU.
Thousands of organizations that do business in California will now have to provide assurance-ready carbon emissions data — including reporting on scope 3 emissions from up and down their value chains. California’s new laws cement the shift from voluntary climate reporting to mandatory reporting, raising the bar for corporate climate action. Corporate leaders who develop strong climate reporting capabilities with audit-ready carbon accounting will be best positioned to meet these California requirements and similar regulations emerging around the globe.
Speakers:
Victoria Evans, MS, SCS Engineers National Climate Change Practice Lead
Ms. Evans has over 45 years of professional experience in greenhouse gas emissions (GHG), energy, air quality, and environmental science, working in consulting, R&D, academia, and the federal government. As the current and prior lead for GHG services at major consulting firms, she gained over 25 years of experience in climate and GHG management. She has directed or performed over 300 GHG studies for diverse U.S. and global corporations and governmental organizations. This involved developing both voluntary and mandatory GHG inventories, reporting, California Cap-and-Trade compliance strategies, carbon reduction roadmaps, and life cycle analyses. She has advised on the development of protocols for carbon offset projects and was selected to be a member of the GHGP (Greenhouse Gas Protocol) Technical Working Group for revision of their Corporate Reporting Standards. Victoria has presented frequently on the SEC and California’s GHG/climate disclosure requirements and advises her clients on preparing for compliance.
David Greene, SCS Engineers Project Director
For the past 15 years, David Greene has managed numerous Landfill air emissions, greenhouse gas reporting, renewable energy compliance and due diligence efforts, for SCS Engineers. Mr. Greene has delivered a variety of landfill management-related presentations in international settings, visited multiple landfills in Southeast Asia, as well as assisted on landfill gas beneficial use studies for sites in Eastern Europe and South America. He is currently serving as a coordinator for A&WMA’s Sustainability, Climate Change, Resource Conservation, and Waste Management group, presented in previous A&WMA Webinars, and authored several articles in A&WMA’s EM magazine. David is a licensed professional engineer in North Carolina, South Carolina and Tennessee.
David C. Smith, Manatt, Phelps & Phillips Partner
Building and broadening his more than 25 years of expertise in complex entitlement and regulatory compliance at all jurisdictional levels, David secured a Master of Laws in Energy and Climate to counsel clients on all aspects of sustainability, transition to renewable energy, efficiency and storage, and leveraging of federal and state incentives and regulatory mandates. David frequently speaks to and counsels public and private ventures on voluntary and regulatory ESG and other climate-related objectives and strategies. David has written and spoken extensively on California’s climate mandate laws and compliance strategies for companies in all economic sectors.
Certificate of Participation: 1.50
Additional Resources:
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