SB 253

October 28, 2025

Alert for industry to changes in regulations it must comply with.

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.

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

  • CARB has released a draft reporting template for SB 253 (optional in year 1) and an accompanying Memo.
  • 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

 

Additional SB 253, SB 261 Resources:

 

 

 

Posted by Diane Samuels at 11:30 am

August 28, 2025

California Air Resources Board Signals Intentions for Climate Regulations

 

See our October 28, 2025 blog: “UPDATE SB 253, SB 261: California Air Resources Board Provides Resources and Delays Climate Regulations until 2026,” for the most recent updates and important information.

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

Resources:

 

Posted by Diane Samuels at 1:36 pm

April 9, 2025

Alert for industry to changes in regulations it must comply with.

 

 

Your Roadmap for Mandatory Corporate Climate Reporting – SB 253 and SB 261

See our October 28, 2025 blog: “UPDATE SB 253, SB 261: California Air Resources Board Provides Resources and Delays Climate Regulations until 2026,” for the most recent updates and important information.

Do you represent one of the 10,000 companies in the U.S. doing business in California that will be affected by sweeping new climate-related disclosure requirements recently signed into law?

California requirements for public disclosures cover corporate climate-related financial risk (SB 261) and corporate GHG emissions/targets (SB 253). While these state climate disclosure laws are subject to court challenges, they are still in effect, so companies are collecting data now.

 

Corporate Climate Reporting will impact public and private companies in the U.S. doing business in California, including companies headquartered outside of the state.

 

If you reply yes to the questions below, you must report your company’s Climate Disclosure starting in 2026.

  1. The company’s gross revenue is over $500M annually (SB 261) or over $1B annually (SB 253)
  2. The company’s ‘doing business in California’ under state tax law, for example, meeting the threshold for payroll compensation in California of over $73.5K annually.

This live educational webinar will highlight these new disclosure requirements for climate disclosures, apply the standards, and provide the related assurance requirements for each. This one-hour webinar is free and relevant to all industries. Meet our panelists.

Our panelists will explain the carbon accounting expectations, materiality considerations, and what to do now to prepare. We’ll provide an update on the net impact of timely court decisions affecting California requirements, as well as the impact of similar disclosure requirements under the CSRD rules of the European Union. It’s free with a Q&A forum, it’s non-commercial, and we respect your privacy!

Start or refine your roadmap for the journey to mandatory reporting and reflect upon the relationship of these disclosures to U.S. firms remaining globally competitive.

 

Register Now to reserve a seat for Your Roadmap for Mandatory Corporate Climate Reporting, Presented Live on Wednesday, April 16, 2025, at Noon Eastern Time.

 

Free Resources Include:

 

 

 

Posted by Diane Samuels at 6:00 am

April 2, 2025

 

 

Your Roadmap for Mandatory Corporate Climate Reporting – SB 253 and SB 261

Do you represent one of the 10,000 companies in the U.S. doing business in California that will be affected by sweeping new climate-related disclosure requirements recently signed into law?

California requirements for public disclosures cover corporate climate-related financial risk (SB 261) and corporate GHG emissions/targets (SB 253). While these state climate disclosure laws are subject to court challenges, they are still in effect, so companies are collecting data now.

 

SB 253 and SB 261 will impact public and private companies in the U.S. doing business in California, including companies headquartered outside of the state.

 

If you reply yes to the questions below, you must report your company’s Climate Disclosure starting in 2026.

  1. The company’s gross revenue is over $500M annually (SB 261) or over $1B annually (SB 253)
  2. The company’s ‘doing business in California’ under state tax law, for example, meeting the threshold for payroll compensation in California of over $73.5K annually.

This live educational webinar will highlight these new disclosure requirements for climate disclosures, apply the standards, and provide the related assurance requirements for each. This one-hour webinar is free and relevant to all industries. Meet our panelists.

Our panelists will explain the carbon accounting expectations, materiality considerations, and what to do now to prepare. We’ll provide an update on the net impact of timely court decisions affecting California requirements, as well as the impact of similar disclosure requirements under the CSRD rules of the European Union. It’s free with a Q&A forum, it’s non-commercial, and we respect your privacy!

Start or refine your roadmap for the journey to mandatory reporting and reflect upon the relationship of these disclosures to U.S. firms remaining globally competitive.

 

Register Now to reserve a seat for Your Roadmap for Mandatory Corporate Climate Reporting, Presented Live on Wednesday, April 16, 2025, at Noon Eastern Time.

 

Free Resources Include:

 

 

 

Posted by Diane Samuels at 6:00 am

March 5, 2025

Do you represent one of the 10,000 companies in the U.S. doing business in California that will be affected by sweeping new climate-related disclosure requirements recently signed into law?

California requirements for public disclosures cover corporate climate-related financial risk (SB 261) and corporate GHG emissions/targets (SB 253). While these state climate disclosure laws are subject to court challenges, they are still in effect, so companies are collecting data now.

The requirements will impact public and private companies in the U.S. doing business in California, including companies headquartered outside of the state.

If you reply yes to the questions below, you must report your company’s Climate Disclosure starting in 2026.

    1. My company’s gross revenue is over $500M annually (SB 261) or over $1B annually (SB 253)
    2. My company’s doing business in California under state tax law, for example, meeting the threshold for payroll compensation in California of over $73.5K annually.

This live educational webinar, now recorded for your convenience, highlights these new disclosure requirements for climate disclosures, applies the standards, and provides the related assurance requirements for each. This one-hour webinar is free, non-commercial, and relevant to all industries. Watch now!

Meet our panelists.

How will SB 253 and SB 261 impact my business?

Our panelists explain the carbon accounting expectations, materiality considerations, and what to do now to prepare. We’ll provide an update on the net impact of timely court decisions affecting California requirements, as well as the impact of similar disclosure requirements under the CSRD rules of the European Union.

You can start or refine your roadmap for the journey to mandatory reporting and reflect upon the relationship of these disclosures to U.S. firms remaining globally competitive.

 

 

Posted by Diane Samuels at 2:02 pm

February 17, 2025

Collecting climate data in 2025 will significantly help meet the 2026 reporting requirements for thousands of companies doing business in California.

 

California is one of the world’s largest economies and drives national and global change. Two new state climate laws have been passed that address climate change’s physical, human, and financial risks. The Climate Corporate Data Accountability Act (SB 253) and The Climate-Related Financial Risk Act (SB 261) impact thousands of organizations that do business in California and must provide assurance-ready carbon emissions data — including reporting on scope 3 emissions from up and down their value chains.

Businesses are already implementing changes to meet the demands of these emerging regulations that cement the shift from voluntary climate reporting to mandatory reporting. Corporate leaders continue to develop strong climate reporting capabilities with audit-ready carbon accounting. They will be well-positioned to meet these California requirements and similar regulations emerging around the globe.

If you’re a large company doing business in California, you must begin gathering emissions data now to meet reporting requirements. Please join SCS Engineers for an A&WMA webinar that will help your company prepare your climate data and the internal processes and controls to manage it for these new regulations.

SB 253 affects public and private businesses with more than $1B in total revenue and doing business in California. SB 261 affects public and private businesses with more than $500M in total revenue and doing business in California.

 

Find out more about SB 253 & 261 during this 90-minute informative discussion.

 

Additional Resources:

See our October 28, 2025 blog: “UPDATE SB 253, SB 261: California Air Resources Board Provides Resources and Delays Climate Regulations until 2026,” for the most recent updates and important information.

 

 

 

 

Posted by Diane Samuels at 4:46 pm

February 17, 2025

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.

March 19, 2025, 1:00 PM Eastern
12:00 PM Central, 11:00 AM Mountain, 10:00 AM Pacific

Register Here

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.

Cost
A&WMA Member Price: $99.00
Full Price: $149.00

Certificate of Participation: 1.50

 

Additional Resources:

 

 

Posted by Diane Samuels at 3:01 pm
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