CARB Opens Platform, Issues Guidance for 2026 Climate Reports

The California Air Resources Board (CARB) released new guidance and a voluntary reporting platform for the inaugural reports under the state's SB 253 climate disclosure law, due November 10, 2026. This development is critical for the thousands of public and private companies with significant operations in California that are now subject to broad greenhouse gas (GHG) emissions reporting. The guidance clarifies compliance pathways for the initial reporting year, reaffirming CARB’s previously announced enforcement discretion. For 2026, companies can submit existing Scope 1 and Scope 2 data without penalty for lacking third-party assurance; those not collecting data as of December 2024 can submit a non-reporting statement. The new online platform is optional and designed to streamline submissions and fee collection. Counsel should advise clients to evaluate the guidance immediately to determine their 2026 reporting approach while closely tracking CARB’s separate, ongoing rulemaking process that will establish permanent, more stringent requirements, including for Scope 3 emissions, for 2027 and subsequent years.