California Details First SB 253 Climate Reporting Rules
The California Air Resources Board has released new guidance and a voluntary reporting platform for inaugural greenhouse gas emissions reports due this fall under the state's landmark corporate climate disclosure law.
The California Air Resources Board (CARB) has issued new guidance and launched a voluntary online platform for companies preparing their first greenhouse gas (GHG) emissions reports under the Climate Corporate Data Accountability Act (SB 253). Although the final implementing regulation awaits approval, CARB is proceeding as if the inaugural reports for Scope 1 and Scope 2 emissions are due November 10, 2026. Sophisticated counsel should note the significant enforcement discretion outlined in the guidance for this first reporting cycle. Companies that were not already collecting GHG data as of December 5, 2024, are not required to generate new data for this deadline; instead, they may submit a “statement of non-reporting.” The guidance also clarifies that third-party assurance, while ultimately required by the statute, will not be a prerequisite for accepted submissions in 2026. Covered entities should immediately evaluate the guidance to determine their specific obligations and prepare for the upcoming filing.