On July 7, the California Air Resources Board (CARB) announced it will hold a virtual public workshop to support the development of the California Corporate Greenhouse Gas Reporting Program authorized by Senate Bill (SB) 253, as amended by SB 219. See the link below.
CARB staff will provide an update on regulatory concepts for Scope 1 and 2 greenhouse gas (GHG) emissions reporting requirements for 2027 and beyond, including data assurance. Staff will also discuss CARB’s proposed approach for Scope 3 emissions reporting beginning in 2027 (summarized below).
The workshop will be held virtually on Zoom (only) on Tuesday, July 21, 2026, at 9:30 am – 12:30 pm (Pacific Time). Register for virtual attendance.
Workshop materials are to be posted to the California Corporate Greenhouse Gas (GHG) Reporting and Climate Related Financial Risk Disclosure Programs webpage on July 20, 2026. Staff plans to take verbal feedback during the workshop, with written feedback to be sent to .
CARB’s Proposed Options for Scope 3 Reporting (March 23, 2026, Workshop)
Option 1: Starting in 2027, all Scope 3 categories
Option 2: Industry Sector Phase-In for 2027
Option 3: Category Phase-In for 2027
Recap of Program
The California Corporate Greenhouse Gas Reporting Program under SB 253 requires U.S.-based companies, with total annual revenues exceeding one billion dollars ($1,000,000,000) that do business in California, to annually disclose their Scope 1, Scope 2, and Scope 3 emissions for their prior fiscal year. SB 253 requires that the initial (first-year) annual emissions disclosures in 2026 address Scope 1 and Scope 2 emissions, and, in subsequent years (beginning in 2027), include Scope 3 emissions.
For Details
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On June 24, the California Air Resources Board (CARB) announced a 3-month extension in the reporting deadline for covered companies for their first year reporting of corporate Scope 1 and Scope 2 greenhouse gas (GHG) emissions. The due date has been moved from August 10 to November 10, 2026.
The extension will be reflected in an updated regulatory proposal to give companies additional time following the formal adoption of CARB’s pending SB 253 and SB 261 regulations. The CARB Board approved the initial regulation on February 26, 2026.
CARB also announced that it will propose limited changes to the regulation to clarify certain requirements and will make them available for comment as part of a forthcoming 15-day public comment period.
Because this step may delay the finalization of this regulatory package, CARB proposed, as part of this 15-day change, a three-month deferral of the reporting deadline. The new proposed reporting deadline of November 10 will help ensure reporting entities have additional clarity following approval of the final regulation before reporting is due.
Recap of Program
The California Corporate Greenhouse Gas Reporting Program, established by SB 253 (codified in HSC § 38532), requires U.S.-based companies, with total annual revenues exceeding one billion dollars ($1,000,000,000) that do business in California, to annually disclose their Scope 1, Scope 2, and Scope 3 emissions for their prior fiscal year. SB 253 requires that the initial (first-year) annual emissions disclosures in 2026 address Scope 1 and Scope 2 emissions, and, in subsequent years (beginning in 2027), include Scope 3 emissions.
For Details Visit – California Corporate Greenhouse Gas Reporting: Notice of Upcoming Rulemaking Update to Further Clarify Requirements and Deferring 2026 Reporting Deadline
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What happened at the February 26, 2026, California Air Resources Board (CARB) public hearing and meeting?
On Thursday, February 26, CARB voted to approve regulations implementing California’s two climate disclosure requirements. To implement these laws, the board approved the draft regulation, which provides key definitions, establishes annual compliance fees, and sets deadlines for the first year of reporting.
What are the key elements of the new regulation?
Since these regulations were just issued, what enforcement is expected in 2026?
CARB emphasized that its enforcement guidance remains in effect, which provides accommodation for the first year of reporting. In its press release following the hearing, CARB noted that its priority is to support compliance through stakeholder engagement, and it will exercise enforcement discretion as long as good-faith efforts are made in first-year submissions.
When are climate risk disclosures under SB 261 due?
Enforcement of SB 261 is on a Ninth Circuit injunction, as acknowledged by CARB at the hearing. That injunction does not extend to SB 253. More than 120 climate-related financial risk reports have been voluntarily submitted and are publicly available at CARB’s SB 261 public docket.
What are the plans for future regulations under these laws?
CARB staff noted that additional topics are to be addressed in future guidance, with further SB 253 regulations to be proposed later this year. These are to address Scope 3 GHG emissions reporting, assurance, and reporting deadlines in 2027 and beyond.
CARB SB 253 and SB 261 Resources
See below for links to the notice of staff meeting presentation, the adopted regulatory text, and the press release, along with contact information for subject-matter experts should you require further assistance.
CARB Updates to California’s SB 253 and SB 261 climate reporting and verification. For the most current information see SCS’s answers to the most frequently asked questions.
SB 261: Requires companies to publish a climate-related financial risk disclosure every two years, with the first report due by January 1, 2026. On November 18, the Ninth Circuit Court of Appeals issued an injunction temporarily halting implementation of SB 261. The injunction is in place pending appeal, e.g., until the Ninth Circuit rules on the merits.
SB 253: Requires companies to report their Scope 1, 2, and 3 greenhouse gas (GHG) emissions with phased-in compliance, beginning in 2026, but recently announced these updates, as follows:
CARB anticipates issuing detailed regulations in Q1-2026. Stay tuned for updates from SCS.
Additional SB 253 and SB 261 Resources:
See the most recent program updates.
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. For the most current information, see SCS’s answers to the most frequently asked questions.
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 implementation resources for SB 253 and 261, as well as 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:
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.
If you reply yes to the questions below, you must report your company’s Climate Disclosure starting in 2026.
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:
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.
If you reply yes to the questions below, you must report your company’s Climate Disclosure starting in 2026.
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:
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.
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.
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.
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