California Issues Key Updates for 2026 GHG Reporting
The California Air Resources Board has deferred the initial reporting deadline for corporate greenhouse gas emissions to November 10, 2026, and clarified that Scope 3 reporting is not required for the first year.
The California Air Resources Board (CARB) has issued modified regulations and new guidance for its landmark Climate Corporate Data Accountability Act (SB 253), which compels large companies doing business in the state to report greenhouse gas (GHG) emissions. The first reporting deadline for Scope 1 and Scope 2 emissions has been deferred to November 10, 2026, and Scope 3 reporting is not required for the inaugural year. The updates also clarify rules on parent-level consolidation and exclude certain wholesale electricity and intercompany transactions. For 2026 only, companies have flexible reporting options, including using existing reports or a CARB template; some may only need to submit a letter stating they were not collecting data as of a key date. This regulation impacts public and private entities with over $1 billion in annual revenue, creating immediate compliance obligations. Counsel should advise affected clients to assess their 2026 reporting requirements and prepare submissions for the November deadline, while also monitoring parallel constitutional challenges to California's related SB 261 financial-risk disclosure law.