Recent Updates to California’s SB 253 and 261 Climate Regulations
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
Given the large volume of public comments, CARB proposes bringing the initial rulemaking, including the fee-related provisions, to the board in Q1 2026.
CARB invites feedback on the preliminary list of covered entities to be submitted through an online survey. Other comments or inquiries can be submitted to .
October 10 –Corporate GHG Template and Memo for SB 253 published
CARB solicited comments here through Oct 27, with SCS submitting comments to improve clarification of Emission Factors applied and anticipate changes coming in revisions scheduled for the GHG Protocol’s guidance.
September 2 – Climate-Related Financial Risk Disclosures Draft Checklist
While the rulemaking may be delayed until next year, there has been no formal delay to the January 1, 2026, deadline for disclosure under SB 261.
CARB provides significant flexibility for applying alternative standards from the TCFD, IFRS, and other frameworks used elsewhere in governmental reporting.
The public docket for posting the corporate link to CA SB 261 reports will be open through July 1, 2026 – this may be subject to change since the rulemaking timeline is updated.
Information from CARB’s August Public Workshop for 2026
Definition of Covered Companies – the “Who”
Alternative definition of annual Revenue consistent with Dunn & Bradstreet, Standard & Poor, and Data Axle. [Thresholds – Risk >$500M; GHG: >$1B]
Update on definition of Doing Business in CA: Companies in the California Secretary of State Business Entity public database.
Update on definition of Parent and subsidiary: Use the existing AB 32 definition. Working on a process for companies to avoid reporting for multiple entities under the same parent company.
Allows parent companies to report at a consolidated level when appropriate. Proposed specific exemptions were identified.
Due Dates
Climate Risk: Per the due date specified in the legislation, the first climate-related financial risk report is due January 1, 2026, then biennially.
GHG Emissions: Corporate Scope 1 and 2 reporting is due June 30, 2026 (covering FY 2025) with verification at Limited Assurance.
SB 261 Disclosure/Reporting Content
For 2026 reporting, the GHG Inventory basis can be the most recent year available, such as 2024 or 2023, if 2025 is unavailable. Scope 3 reporting is not mandatory for 2026, but recommended if it is material.
Preliminary Estimate of Covered Companies and Estimated Annual Fees (subject to change)
SB 261 Risk: 4,160 companies with $1,403 annual fee
Sb 253 GHG: 2,596 companies with $3,106 annual fee
Assurance by 3rd parties
GHG: CARB’s initial concepts include potential alignment with existing international standards: ISSA 5000 (IAASB); AA1000; ISO 14060 family, and AICPA.
CARB may opt in to audit assurance and reporting. CARB retains authority for review and enforcement actions.
Next Steps:
Board consideration of proposed rulemaking: Q1 2026
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”
NEW – Alternative definition of annual Revenue consistent with Dunn & Bradstreet, Standard & Poor, and Data Axle. [Thresholds – Risk >$500M; GHG: >$1B]
NEW – Update on definition of Doing Business in CA: Companies in CA Secretary of State Business Entity public database.
NEW – Update on definition of Parent and subsidiary: Use existing AB 32 definition. Working on process for companies to avoid reporting for multiple entities under same parent company.
NEW: Allows parent companies to report at a consolidated level when appropriate. Proposed specific exemptions were identified.
Due Dates
Climate Risk: NO change since a legislative requirement: First climate-related financial risk report is due January 1, 2026, then biennially.
GHG Emissions: NEW – Corporate Scope 1 and 2 reporting is due June 30, 2026 (covering FY 2025) with verification at Limited Assurance.
Disclosure/Reporting Content
Climate Risk: NEW – May meet one of several standards: TCFD, IFRS, or report developed under other regulations. And, CARB to host a public docket open from December 1, 2025 to July 1, 2026 for entities to post the public link to their reports.
For 2026, GHG Inventory basis can be 2024 or 2023, if 2025 is not available. Scope 3 reporting is not mandatory for 2026 but recommended if material.
GHG: NEW – CARB will post draft reporting templates for Scope 1 and 2 reporting by the end of September 2025 for public feedback.
Preliminary Estimate of Covered Companies and Estimated Annual Fees
Risk: NEW – 4,160 companies with $1,403 annual fee
GHG: NEW – 2,596 companies with $3,106 annual fee
Assurance by 3rd parties
GHG: NEW – CARB’s initial concepts provided include potential alignment with existing international standards: ISSA 5000 (IAASB); AA1000; ISO 14060 family and AICPA. CARB may opt to audit assurance and reporting. CARB retains authority for review and enforcement actions.
Next Steps
Public comment period – ends Sept 11, 2025
Notice of Proposed Rulemaking – Oct 14, 2025
45-day Public Comment period – Oct 17 – Nov 30, 2025
Board consideration of proposed rulemaking: Dec 11 — Dec 12, 2025
