On October 12, 2026, the California Office of Administrative Law approved the California Air Resources Board’s (CARB) initial climate disclosure regulations, effective immediately. The first annual Scope 1 and Scope 2 greenhouse gas (GHG) emissions reports under SB 253 are due November 10, 2026. Enforcement of SB 261’s climate-related financial risk disclosure requirements remains suspended pending appeal.

With the reporting deadline approaching, companies should focus on three points:

• Who and what is covered. SB 253 generally covers public and private U.S.-formed entities doing business in California with more than $1 billion in annual revenue, subject to applicable definitions and exemptions. First-year reports cover the applicable prior fiscal year’s Scope 1 emissions (direct emissions from company-owned or controlled sources) and Scope 2 emissions (indirect emissions from purchased electricity, steam, heating, and cooling). Scope 3 reporting, covering other indirect value-chain emissions, is scheduled to begin in 2027.
• Resources and submission options. CARB’s reporting guidance and FAQs explain how to prepare first-year submissions. Companies may submit their emissions report or a statement of non-reporting, if applicable, along with contact information through CARB’s Report Intake Platform or by email to climatedisclosure@arb.ca.gov.
• First-year relief and documentation. Under CARB’s December 2024 Enforcement Notice, companies may report using information they possessed or were collecting as of December 5, 2024, even without limited assurance (independent third-party review). Companies that were neither collecting nor planning to collect Scope 1 and Scope 2 data at that time should submit a statement of non-reporting on company letterhead explaining those circumstances. Companies relying on relief should document their eligibility and good-faith compliance efforts.

For more on SB 253, SB 261, and CARB’s implementation and reporting guidance, please see our prior client alerts.