Mayer Brown·ENVIRONMENT / ESG / CLIMATE

CARB Finalizes California Climate Disclosure Rule Updates, Delays 2026 SB 253 Deadline

US companies doing business in California with over $1 billion in global annual revenue (subject to SB 253) and over $500 million (subject to SB 261) must update compliance plans after CARB finalized modified climate disclosure rules delaying the 2026 Scope 1/2 reporting deadline to November 10, 2026, and previewed 2027 Scope 3 and assurance mandates.

CARB released modified regulations for California’s SB 253 (Climate Corporate Data Accountability Act) and SB 261 (Climate-Related Financial Risk Act) after withdrawing its initial 2026 rulemaking, with a 15-day public comment period ending August 11, 2026. Key changes include a three-month delay to the 2026 Scope 1 and 2 reporting deadline (now November 10, 2026), no Scope 3 reporting requirement for 2026, and clarified applicability and revenue calculation rules. SB 261 enforcement remains paused pending ongoing Ninth Circuit litigation. CARB also previewed 2027 rulemaking including limited third-party assurance for Scope 1/2, removal of the insurance company SB 253 exemption, and fiscal year-aligned reporting timelines. Covered entities should review the modified rules, adjust compliance timelines, and monitor 2027 rulemaking developments.

california-climate-disclosurecarb-rulemakingsb-253sb-261scope-3-reporting
Read the original firm alert →Thursday, August 6, 2026

Stay ahead

Join the digest.

One email when the daily AmLaw 100 briefing ships. No noise, no pitch decks — just the grade 4–5 signal.