Updates to Corporate Greenhouse Gas Reporting (SB 253) and Climate-Related Financial Risk Disclosure (SB 261)

March 5, 2026

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?

  • Definitions for “doing business in California,” “revenue,” “parent,” and “subsidiary” follow the approaches CARB described at its November 2025 public workshop.
  • The deadline was set for August 10, 2026, for first-year Scopes 1 and 2 GHG emissions reporting under SB 253. The regulation provides a cut-off for determining the applicable fiscal year for reporting. Overall, companies have 6-18 months to submit a GHG inventory report from the close of their fiscal year (FY). If their FY is a 12-month calendar year, FY 25 is to be reported in 2026. If a company’s FY ends Jan 31, 2026, data from FY 25-26 are to be reported in 2026. If a company’s FY ends Feb 2, 2026, data from FY 24-25 are to be reported.
  • The fee structure and calculation formula for each of the two. CARB staff estimated fees at $2,000 to $7,000 per in-scope company, depending upon which law applied.
  • Excluded are insurance companies, entities whose only business in California is employee compensation or payroll expenses, non-profits, and government entities, and a business entity whose only activity within California consists of wholesale electricity transactions.

 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.

 

 

 

Posted by Diane Samuels at 8:22 am
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