CARB Rule Approved, Locking Nov. 10, 2026 SB 253 Climate Filing Deadline

California's Office of Administrative Law approved CARB's climate-disclosure Initial Regulation on October 12, 2026, effective immediately and codified at Title 17 CCR sections 96070-96077. Administrative review is complete, so the first-year SB 253 deadline for Scope 1 and 2 emissions is now fixed at November 10, 2026, not the earlier August 10 date, leaving covered filers under a month.

Two points matter. First, CARB's reminder letters, posted October 9, are informational only: receipt or absence is not a scope determination, and entities that received none may still be in scope. First-year guidance allows filers to reuse an existing annual report, data already reported to other programs, or CARB's template, with no third-party assurance required, and permits a non-reporting statement for entities not collecting Scope 1 or 2 data on or before December 5, 2024. Companies with fiscal years ending January 1 through February 1, 2026 report fiscal 2026 data instead.

Second, approval does not resolve litigation: SB 261 remains under a Ninth Circuit preliminary injunction that does not reach SB 253, and the parties notified the court of the approval under FRAP 28(j). Clients should confirm filing status now, document good-faith compliance efforts, and watch CARB's 2027 rulemaking, which previewed phased Scope 3 categories and limited assurance.